erly - Privacy Policy
|
Last updated: November 2021 erly is owned by OWNA Corp Pty Ltd (ACN 613 387 474 ABN 39 613 387 474), and adheres to OWNA’s existing Policies in addition to the following. In summary we take your privacy and security seriously. We do not sell your data to any third party organisation and the content uploaded to erly is your content. At OWNA Corp Pty Ltd (“OWNA”) we understand the importance of privacy and its security to you. We take privacy very seriously and are committed to dealing with Personal Information in accordance with the requirements of the Privacy Act 1993 (NZ), the Privacy Act 1988 (Cth, Australia) and any other applicable privacy legislation. From time to time we will review our Privacy Policy to keep pace with changes in our service. Please take a moment to read this Privacy Policy so you understand how we collect, store, use and disclose Personal Information. By providing your Personal Information to erly, you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy. 1. Definitions - “We”, “Us”, “Our”, “erly” or “OWNA” refers to OWNA Corp Pty Ltd ACN 613 387 474 ABN 39 613 387 474 of Suite 213, 29-31 Lexington Drive, Bella Vista NSW 2153. - “You”, “Your” or “Customer” means any User of the Website or Services. - “Service/s” means Our Software, Products, Website, Portal or associated goods and services We make available to You through the website. - “Software” means Our software licensed as part of the Services. - “Website” or “Application” means this website, erly.app, theworkr.app, owna.com.au and other websites We have or establish for Your use. - “Personal Information” means information about a person from which their identity is apparent or can reasonably be determined. - “Data” or “Content” means any Personal Information that is collected and stored. 2. Application This Privacy Policy applies to all Personal Information obtained by erly, including, but not limited to when submitted by Users of our Website and/or the application(s) that erly offers including through the Website (each an “Application”). 3. Collection and Storage of Personal Information and Data By accessing the Website or using the Application, all such Users consent to the collection, use, disclosure, storage and processing of their information in accordance with this Privacy Policy. We may collect Personal Information (being information about a person from which their identity is apparent or can reasonably be determined). This information can include names, dates of birth, email addresses, home and work addresses, telephone numbers, bank account details, payment information and employment information. We may collect Personal Information in circumstances including: - From you directly when you provide information to us (whether face to face or otherwise); - When an individual signs up or registers to use the Application; - When you visit our website we may ask you to provide personal data to us, for example contact information; - When you enter into a transaction with us using a credit card or method of payment other than cash; - When you interact with us on social media, visit our website and send an enquiry through or make a comment or other post at the Website; - When you sign up or subscribe to an email marketing list; - When we meet with an organisation wishing to do business with us (and an individual from that organisation provides Personal Information about themselves); and - When evaluating job applicants and personnel which may include collection of details such as employment history and educational qualifications. This may include “sensitive information”. 4. Use of Personal Information We use Personal Information about you to operate our Application and to provide you with services as requested. We may use your personal data for other purposes including in the following ways: - To communicate with you and provide you (including through functionality provided with an Application) with information (whether by email, post or other means) about our services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the relevant legislation including under the Australian Privacy Principles, the Privacy Act 1993 (NZ), the Personal Information Protection and Electronic Documents Act (Canada) and other applicable legislation. - To respond to enquiries received from you; - To perform authorised financial transactions with you and to help us to manage our accounts and administrative services; - To verify your identity; - To notify you about changes to our services; - To receive and address feedback or complaints from you; - To protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary); - To produce analytics and reporting; and - In other circumstances, with your prior consent. All those with whom we interact have the option to opt-out of receiving marketing communications from us. If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you. You acknowledge that some features of the Application may involve us providing through the Application recommendations or suggestions for goods, services or benefits that we offer. We may use Personal Information for the purpose of marketing but only where such use complies with privacy legislation in effect in the relevant territory. We may, subject to legislative requirements, send occasional emails to you in relation to our current or future services. Any such emails will contain an unsubscribe link, enabling you to opt-out of these messages. We take steps to regularly destroy data (being Personal Information and sensitive information) that does not need to be archived and to de-identify stored data where identification of a person is not reasonably required or necessary. 5. Disclosure of Personal Information We will not sell your Personal Information to anyone. We share your Personal Information outside our organisation for limited purposes, such as to help us run our business and provide services. Those persons and business include: - Organisations who carry out credit, fraud and other security checks; - IT support providers; - Actual or potential parties in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and - Marketing businesses engaged by us to disseminate materials to which recipients have consented. We may also disclose your Personal Information to third parties outside our organisation: - Where we have your express permission to do so or it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties; - Where you are a User- and the third party in question is your employer, being the Centre who controls/ maintains the Centre Account to which your User Profile relates – in response to a request from the Centre to access that User Profile or other related Personal Information; - If erly or substantially all of its assets were acquired by a third party, in which case Personal Information which we hold may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and - If we are under a duty or have a legal right to disclose or share Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect our rights, property, or the safety of our personnel and Users. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling your Personal Information, and use your Personal Information only for the purposes that we give it to them. 6. Security of Personal Information We take all reasonable steps to protect Personal Information, including through internal and external security, restricting access to Personal Information to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We choose technology partners based on their security and privacy policies and practices. Personal Information stored in our system is protected by electronic and procedural safeguards. We take reasonable precautions to protect Personal Information (and other content) from accidental loss and theft by storing it in secure data centres with off-site backups. Communication between Users and our servers are encrypted using industry- standard security measures such as TLS 1.2 and SSL. The Application is protected by a secure password which a User may choose themselves. Users should never share their passwords. erly is not responsible for any loss of data or breach of privacy if a User shares their password with someone else. We do not store your password on our servers. erly takes all reasonable precautions to protect your data. Because internet transmissions cannot be guaranteed to be 100% secure, you acknowledge and agree that you use this service at your own risk. In case of a breach of security safeguards, such as the loss of, unauthorized access to or unauthorized disclosure of Personal Information under erly’s control, and if the breach poses a real risk of significant harm to you, we will notify you and the appropriate federal authorities in Australia, as well as any other organization that may reduce the risk or mitigate the harm from the breach. 7. Questions and concerns and access to/ correction or updating of your Personal Information You have a right to access the Personal Information we hold about you. To obtain a copy of the Personal Information we hold about you, or to update it, please write to us at: The Privacy Officer erly Suite 213, 29-31 Lexington Drive Bella Vista NSW 2153 or by email to: support@erly.app Please provide sufficient detail about the information in question to help us locate it. We will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time. If a fee is charged for such access we will advise you of the cost in advance. If you wish to complain about a breach of privacy legislation or have any questions about how we handle Personal Information please contact our Privacy Officer. 8. Statistical Information We may collect statistical (non-personal) information about your use of the Website and Application to improve the features and overall experience for our Users. The information erly may collect includes statistical information such as pages accessed on the Website and Application, search terms, links that are clicked on, Website and Application visit times, browsers and operating systems, IP address, and cookies. The Website does not currently recognize Do Not Track (DNT) signals sent by our Users’ web browsers. However, we do not collect any of our Users’ personally identifiable information pertaining to their activity over time and across other websites or online services. In addition, third parties that have content embedded on the Website, such as videos or social media buttons, may set cookies on a User’s browser and/or obtain information about the fact that a web browser visited the erly website from a certain IP address. 9. Cancelling your Account If your erly account terminates (for whatever reason), the Personal Information associated with it may no longer be accessible to you. Any Content you have posted from your account may still be available to other people associated with your account. There may continue to be residual copies of such Content due to ongoing data back-up and archiving. 10. Retention of Data erly will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. |