This Privacy Policy governs how SPLOSE PTY LTD ACN 614 286 636 (we, us, our) will deal with your personal information (as defined under the Privacy Act) and sensitive information (as defined in clause 6(a) of this Privacy Policy and the Privacy Act) (collectively, Personal Information) collected in connection with the provision of our software application known as ‘splose’ (Platform), and such other products and services as may be provided through our website at https://splose.com/ (Website) and any other technological means from time to time (Services). We are the controller of (and are responsible for) your Personal Information.

This Privacy Policy also applies to Personal Information collected by us in connection with our Platform, as well as in connection with any direct communication between you and us.

We use third parties located both locally and overseas in addition to our own resources to provide these Services.

1 Scope

(a) We understand that when accessing our Services, the privacy and confidentiality of Personal Information is important to you and your customers. That’s why we fully respect your rights to privacy and are committed to protecting the personal and financial details you provide us in line with this Privacy Policy. This Privacy Policy applies to our Services and all individuals who use our Services or whose Personal Information is processed by us.

(b) We are committed to protecting the privacy of everyone who uses our Platform and/or our Services, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act), the General Data Protection Regulation (EU) 2016.679 (GDPR) and the UK General Data Protection Regulation (UK GDPR)

(c) It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

2 Types of information collected

(a) We may collect Personal Information that allows us to identify who an individual is and share Personal Information.

(b) The types of information we may collect includes:

We may also collect Personal Information about third parties from you, such as Personal Information about your family members, so that we can provide products and services to those third parties. If you provide Personal Information about a third-party individual to us, you must ensure that the third-party individual is aware of this Privacy Policy, understands it and agrees to accept it. If you provide Personal Information about a third-party individual and that individual does not have the capacity to understand and agree to these terms (for example, a minor), we require a parent or guardian to acknowledge and agree to this paragraph. The acknowledgement will be through the acceptance of the Terms of Service of the Platform.

(i) Personal Details - We may collect personal details such as an individual’s name, location, date of birth and, nationality and other identification details (e.g. passport or driver’s licence) allowing us to identify who the individual is;

(ii) Contact Information - We collect information such as an individual’s email address, telephone and fax number, geo-location, Internet Protocol (IP) address, unique device identifiers, your mobile number, your device model and name, your operating system, your browser type third-party user names, residential, business and postal address and other information that allows us to contact the individual;

(iii) Financial Information - We collect financial information such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services; and

(iv) Statistical Information - We collect behavioural and statistical information about an individual and businesses in connection with the Services and/or the Platform.

We may also collect Personal Information about third parties from you, such as Personal Information about your family members, so that we can provide products and services to those third parties. If you provide Personal Information about a third-party individual to us, you must ensure that the third-party individual is aware of this Privacy Policy, understands it and agrees to accept it. If you provide Personal Information about a third-party individual and that individual does not have the capacity to understand and agree to these terms (for example, a minor), we require a parent or guardian to acknowledge and agree to this paragraph. The acknowledgement will be through the acceptance of the Terms of Service of the Platform.

3 Collection of Anonymous Information

(a) In order to measure the success of our online advertising we may use pixels, or transparent GIF files, to establish which of our online adverts successfully bring people to our Website and/or Platform. The GIF files are provided by third parties who provide us with online advertising analysis. This system places a cookie on your browser when you enter our Website and/or Platform via online advertisements allowing us to see which online advertisements bring us the most visitors to our Website and/or Platform. Most web browsers automatically accept cookies but you can change your browser to reject them. It is still possible to access our Website and/or Platform without having cookies enabled.

(b) The information collected on our behalf is anonymous and does not personally identify you, which, for statistical purposes includes:

(i) your server address;

(ii) your top level domain name (e.g. .com, .gov, .au, etc.)

(iii)the date, time and length of your visit to the Website and/or Platform;

(iv) the pages you accessed;

(v) the previous website you visited;

(vi) the type of browser you are using; and

(vii) the protocol version used (e.g. HTTP, FTP).

4. How information is collected

9A)Personal Information is collected in association with your use of the Services, an enquiry about us or generally dealing with us directly or via our Platform, including but not limited to:

1. when you purchase products or services from us;

2. when you register for an account on our Platform;

3. when you contact us via our social media pages;

4. when you contact us with an enquiry or complaint in relation to our services;

5. when authorised people provide us with your Personal Information on your behalf;

6. when you attend one of our events;

7. through your access and use of our Platform;

8. when you apply for a job with us; and

9. from third parties including data analysis agencies.

10. As you interact with us or our Platform, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies

5. Use and disclosure of personal information

5.1 General use and disclosure

1. We may disclose your Personal Information to:

   1. our employees, related bodies corporate, contractors or service providers for the purposes of operating our Platform or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, suppliers and manufacturers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, archivists and professional advisors such as accountants, solicitors, business advisors and consultants;

   2. suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;

   3. government and regulatory bodies and law enforcement agencies; and

   4. any other organisation for any authorised purpose with your express consent, including your insurers and your solicitors.

2. We will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission or as otherwise outlined in this Privacy Policy. Most commonly, we will use your Personal Information in the following circumstances:

   1. where we need to perform the contract we are about to enter into or have entered into with you;

   2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

   3. where we need to comply with a legal obligation.

3. We have set out below a description of the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

This Privacy Policy governs how SPLOSE PTY LTD ACN 614 286 636 (we, us, our) will deal with your personal information (as defined under the Privacy Act) and sensitive information (as defined in clause 6(a) of this Privacy Policy and the Privacy Act) (collectively, Personal Information) collected in connection with the provision of our software application known as ‘splose’ (Platform), and such other products and services as may be provided through our website at https://splose.com/ (Website) and any other technological means from time to time (Services). We are the controller of (and are responsible for) your Personal Information.

This Privacy Policy also applies to Personal Information collected by us in connection with our Platform, as well as in connection with any direct communication between you and us.

We use third parties located both locally and overseas in addition to our own resources to provide these Services.

1 Scope

1. We understand that when accessing our Services, the privacy and confidentiality of Personal Information is important to you and your customers. That’s why we fully respect your rights to privacy and are committed to protecting the personal and financial details you provide us in line with this Privacy Policy. This Privacy Policy applies to our Services and all individuals who use our Services or whose Personal Information is processed by us.

2. We are committed to protecting the privacy of everyone who uses our Platform and/or our Services, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act), the General Data Protection Regulation (EU) 2016.679 (GDPR) and the UK General Data Protection Regulation (UK GDPR).

3. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

2 Types of information collected

1. 1. We may collect Personal Information that allows us to identify who an individual is and share Personal Information.

   2. The types of information we may collect includes:

      1. Personal Details - We may collect personal details such as an individual’s name, location, date of birth and, nationality and other identification details (e.g. passport or driver’s licence) allowing us to identify who the individual is;

      2. Contact Information - We collect information such as an individual’s email address, telephone and fax number, geo-location, Internet Protocol (IP) address, unique device identifiers, your mobile number, your device model and name, your operating system, your browser type third-party user names, residential, business and postal address and other information that allows us to contact the individual;

      3. Financial Information - We collect financial information such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services; and

      4. Statistical Information - We collect behavioural and statistical information about an individual and businesses in connection with the Services and/or the Platform.

   3. We may also collect Personal Information about third parties from you, such as Personal Information about your family members, so that we can provide products and services to those third parties. If you provide Personal Information about a third-party individual to us, you must ensure that the third-party individual is aware of this Privacy Policy, understands it and agrees to accept it. If you provide Personal Information about a third-party individual and that individual does not have the capacity to understand and agree to these terms (for example, a minor), we require a parent or guardian to acknowledge and agree to this paragraph. The acknowledgement will be through the acceptance of the Terms of Service of the Platform.

3 Collection of Anonymous Information

1. In order to measure the success of our online advertising we may use pixels, or transparent GIF files, to establish which of our online adverts successfully bring people to our Website and/or Platform. The GIF files are provided by third parties who provide us with online advertising analysis. This system places a cookie on your browser when you enter our Website and/or Platform via online advertisements allowing us to see which online advertisements bring us the most visitors to our Website and/or Platform. Most web browsers automatically accept cookies but you can change your browser to reject them. It is still possible to access our Website and/or Platform without having cookies enabled.

2. The information collected on our behalf is anonymous and does not personally identify you, which, for statistical purposes includes:

   1. your server address;

   2. your top level domain name (e.g. .com, .gov, .au, etc.)

   3. the date, time and length of your visit to the Website and/or Platform;

   4. the pages you accessed;

   5. the previous website you visited;

   6. the type of browser you are using; and

   7. the protocol version used (e.g. HTTP, FTP).

4 How information is collected

1. Personal Information is collected in association with your use of the Services, an enquiry about us or generally dealing with us directly or via our Platform, including but not limited to:

   1. when you purchase products or services from us;

   2. when you register for an account on our Platform;

   3. when you contact us via our social media pages;

   4. when you contact us with an enquiry or complaint in relation to our services;

   5. when authorised people provide us with your Personal Information on your behalf;

   6. when you attend one of our events;

   7. through your access and use of our Platform;

   8. when you apply for a job with us; and

   9. from third parties including data analysis agencies.

2. As you interact with us or our Platform, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies

5 Use and disclosure of personal information

5.1 General use and disclosure

1. We may disclose your Personal Information to:

   1. our employees, related bodies corporate, contractors or service providers for the purposes of operating our Platform or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, suppliers and manufacturers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, archivists and professional advisors such as accountants, solicitors, business advisors and consultants;

   2. suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;

   3. government and regulatory bodies and law enforcement agencies; and

   4. any other organisation for any authorised purpose with your express consent, including your insurers and your solicitors.

2. We will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission or as otherwise outlined in this Privacy Policy. Most commonly, we will use your Personal Information in the following circumstances:

   1. where we need to perform the contract we are about to enter into or have entered into with you;

   2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

   3. where we need to comply with a legal obligation.

3. We have set out below a description of the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.