Privacy Policy

Last Modified: 24.03.2015

1. Privacy Statement

Twily Pty Ltd ACN 162 407 132 (we, us, our) is subject to the Privacy Act 1988 (Cth) (Privacy Act).   Your privacy is important to us and we take our responsibility to protect your personal information seriously.

2. Purpose

This Privacy Policy (Policy) sets out how we collect, hold, use and disclose information about individuals who interact with us or who use any of our products or services. We treat all information of a personal nature that is collected by us in accordance with this Privacy Policy.

3. Personal information collected by us

During the course of conducting our operations, we may collect personal information, some of which given the nature of our service and products may also be sensitive information. Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained.

We collect a wide variety of personal information that is reasonably necessary for the purposes of conducting and improving our business, our products and our services. This information is collected from a wide variety of sources, including:
(a) through our website (www.twily.com.au) (Site);
(b) through our application <TWILY> (App);
(c) through the account creation process;
(d) from our clients;
(e) from marketing research including surveys;
(f) from competitions;
(g) from conducting business or intending to conduct business with us, whether past, present or future;
(h) engaging or interacting with our business or planning to engage or interact with our business, for example by: licencing; investing; partnering; supplying; or by being a part of organisations involved in or planning to be involved in such activities or related activities, including external advisers and sub-consultants;
(i) seeking employment with us, having been employed by us or being employed by us; and/or
(j) otherwise having some form of contact with us.
This personal information is collected in a variety of ways, such as by mail, telephone, email, internet and intranet access, personal contact, by use of our products (and features within our products) and through business activities and events.
Personal information collected by us includes:
(a) name;
(b) title;
(c) contact details;
(d) gender;
(e) employer;
(f) industry of employment;
(g) place of residence;
(h) transactional information;
(i) financial information;
(j) location information;
(k) information in relation to education and work history (for job applications or potential sub-consultants); and
(l) logs, which may include information such as your Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the features of our products that you use, activities or actions you do while using our products, the time and date of your visit to our Site or use of our App, the time spent on any pages of our Site and other log related information relating to your use of our Site or App.

4. Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some features of our products.

5. Contributions

(a) We encourage you to share and connect with others on our Site and within our App by writing posts, uploading video and imagery content (Contributing) for the purpose of fostering future acts of kindness or sharing past acts of kindness.
(b) You should be aware that, if you Contribute in a non-private area of the Site or within the App, all information forming a part of your Contribution may be read, copied, used and re-distributed by people you do not know. Please take care when Contributing and do not disclose any sensitive personal information that you do not want others to see.
(c) If you are Contributing in a private area of the Site, this information will be kept private by us and will not be disclosed to any third party in any circumstances, unless we are required to disclose this information by law. Despite this, you should take extreme care whenever Contributing information of a personal nature online. In no circumstances should you record any passwords, security information or financial information on the Site or within the App.

6. Use of personal information

We use personal information for providing, improving and developing our business, our products, our services and to protect our users. We also use personal information for internal management and related purposes, which include:
(a) providing technical support to you with regard to use of our products and services;
(b) promoting and delivering our products to organisations and individuals; and
(c) determining whether an individual is suitable for a position within our business, or as a sub-consultant for a current or future project.
We automatically gather information to monitor the use of our digital products and services. Most of the data we collected is aggregated, and this information is effectively anonymous to us.

Sometimes you will be asked to confirm that you agree to a particular activity, or the collection of your personal information for a specific purpose. Though we usually collect aggregate data, we will make it clear to you if any information is being collected in a way that could personally identify you.

7. Disclosure of personal information

We do not disclose your personal information to any third party, other than those requiring this information to assist us or those that are directly related to the purposes for which the information was collected, including:
(a) to external service providers so that they can provide financial, administrative or other services in connection with the operation and improvement of our business;
(b) to our clients, other users and sponsors so that all can interact through the features of our products;
(c) to our clients, so that they can collate data with respect to their activities conducted through the Site and our App enabling them to analyse the impact of their campaign;
(d) as permitted under the Privacy Act; and
(e) with the individual’s consent or if the individual would reasonably expect that their information would be passed to the person to whom the personal information is disclosed.

8. Protecting your personal information

We take reasonable steps to protect all personal information which we hold (including your personal information) from misuse, interference, loss, unauthorised access, modification or disclosure.

We take reasonable steps and precautions so as to hold personal information securely, whether in electronic or physical form. These steps include secured encrypted servers, password protection for electronic files, securing paper files in locked cabinets and physical access restrictions.

When no longer required, personal information is destroyed or deleted in a complete and confidential manner.

We also take steps to ensure that the personal information we collect is accurate, up-to-date and complete. These steps include maintaining and updating personal information when it is apparent or are otherwise advised by individuals that their personal information has changed.

We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

Notwithstanding that we use our best endeavours to protect all personal information, we cannot completely guarantee the security of your personal information.

9. Analytics and third parties

We may use Google Analytics to track your usage of the Site. Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of the Site, to prepare reports on its activities and share them with other Google services.

Google may use the data collected to contextualise and personalise the ads of its own advertising network. Personal data collected by Google includes Cookie and usage data, which is processed in the USA. You can find Google’s privacy policy here: http://www.google.com.au/policies/privacy/.

Our products may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We confirm that we have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services whatsoever.

You should be aware that your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.

10. Accessing and updating your personal information

If you have established an account with us, your personal information is open and freely available for you to access through our Site and App via www.twily.com/membership following your log on.

If you are an individual who has provided personal information to us outside of our account creation process, you may request access to it at any time. If you wish to obtain access, please send your request by email to us: admin@twily.com.au. Depending upon the personal information you seek to access, you may be asked:
(a) to put your request in writing with evidence of your identity to verify that you are who you say; and/or
(b) to provide further details to assist us in responding to your request in a timely manner;
We will respond to a request for access to personal information within a reasonable period after the request is made.

You may also request a correction or update be made to your personal information being held by us. Please email us at admin@twily.com.au if you wish to make such an information update request other than through our www.twily.com/membership page.

11. Complaints

We strive to ensure our compliance with this Policy and to regularly review our practices against it.

If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Act, we invite you to contact us at admin@twily.com.au. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution to the issue raised.

Please note that you may also make a complaint to the Office of the Australian Information Commissioner (OAIC) about the handling of your personal information. Information on making a privacy complaint can be found on their website at http://www.oaic.gov.au/privacy/making-a-privacy-complaint.

12. Variations

We reserve the right to vary this Policy from time to time without further notice to you. Any variations made will be updated on our Site. We will not reduce your rights under this Policy without providing you with prior notice. It is your responsibility to check our Policy every now and again to ensure you are aware of any changes made to it.

13. Further information

For any further information about this Policy please contact us at admin@twily.com.au.

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