Privacy Policy

This Privacy Policy sets out the practices of SPLOSE PTY LTD ACN 614 286 636 (Splose) in relation to the collection, use, disclosure and handling of personal information.

In order to provide you with the best service we may ask you to provide us with personal information from time to time. Splose respects your personal information, and your privacy is important to us. Splose is committed to maintaining the highest standards to protect your personal information.

We comply with the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs) and if applicable, General Data Protection Regulation (EU) 2016/679 (GDPR). The Privacy Act, APPs and if applicable, the GDPR, govern the way in which Splose must manage your personal information, and this Privacy Policy sets out Splose’s practices in relation to the collection, use, disclosure and handling of personal information.

This Privacy Policy also applies to all employees and contractors of Splose in relation to the collection, storage, use and disclosure of personal information in the workplace.

This Privacy Policy should be read in conjunction with the terms and conditions for the Website (Terms and Conditions). Any person using the Website should familiarise themselves with the Terms and Conditions and Privacy Policy of this Website, and ensure they review it from time to time.

In this Privacy Policy:

(a)     Services means the services provided by Splose to you on the Website;

(b)     Splose, us, we, and our means SPLOSE PTY LTD ACN 614 286 636 its director/s, employees, agents and any other related parties;

(c)     Website means Splose’s website located at http://www.splose.com; and

(d)     you and your refers to anyone who visits and/or uses the Websites and/or the Services.

Operation of our Policy

You will be made aware when any personal information is required that may allow Splose to identify or contact you. Personal information will usually be requested when you register for a particular service with Splose. By consenting, either expressly or impliedly, to Splose processing your personal information, you will be deemed to have read and accepted the terms of this Privacy Policy. Splose will not process your personal information, unless it has your actual or deemed consent. Your personal information will only be used in accordance with this Privacy Policy. You are free at any time to opt out of receiving information from Splose at the end of each communication.

Collection of Personal Information

The personal information that Splose may collect and hold includes (but is not limited to):

  • full name;
  • mailing or street address;
  • email address;
  • telephone number;
  • date of birth;
  • gender; and
  • credit card and/or bank account information.

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect aggregated information about how users use our Website.

Splose will collect personal information directly from you unless it is unreasonable or impracticable to do so. We will only ask you to provide information that is relevant to the service or product that you have requested or to enable us to respond to your enquiry. 

When collecting personal information from you, we may collect it at various stages, including (but not limited to):

  • when you purchase products or services from us;
  • when you register for an account on our Website;
  • when you contact us via our social media pages;
  • when you contact us with an enquiry or complaint in relation to our services;
  • when authorised people provide us with your personal information on your behalf;
  • when you attend one of our events;
  • through your access and use of our Website; and
  • when you apply for a job with us.

We may also collect personal information from third parties including data analysis agencies.

Collection of Anonymous Information

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. 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 via online advertisements allowing us to see which online advertisements bring us the most visitors to our Website. Most web browsers automatically accept cookies but you can change your browser to reject them. It is still possible to access our Website without having cookies enabled. 

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

  • your server address;
  • your top level domain name (e.g. .com, .gov, .au, etc.)
  • the date, time and length of your visit to the Website;
  • the pages you accessed;
  • the previous website you visited;
  • the type of browser you are using; and
  • the protocol version used (e.g. HTTP, FTP).
Purposes for Collecting, Holding, Using and Disclosing your Personal Information

Splose may use personal information about you so that we can provide you with a high quality of customer service.

We collect, hold, use and disclose your personal information for the following purposes:

  • to provide products and/or services to you and to send communications to you;
  • to answer enquiries and provide information or advice about existing and new products or services;
  • to advise you if we relocate;
  • to advise you if our Terms and Conditions or Privacy Policy have been updated or amended;
  • to assess the performance of the Website and to improve the operation of the Website;
  • to assess our customer service and to improve our customer service to you;
  • to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
  • for the administrative, marketing (including direct marketing and marketing research), planning, product or service development, quality control, human resources, educational and research purposes of Splose, its related bodies corporate, contractors or service providers;
  • to provide your updated personal information to our related bodies corporate, contractors or service providers;
  • to update our records and keep your contact details up to date;
  • to process and respond to any complaint or enquiry made by you; and
  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

Splose may contact you regarding anything set out in the above by e-mail, post or telephone.

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 and Conditions of the Website.

From time to time we may use the information you give us for marketing purposes. Other than as required by law, or as set out in this Privacy Policy, we will not disclose information about you to any third party without your permission. Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy. Splose will not use your personal information for any purpose for which you would not reasonably expect us to use your personal information. Additionally, Splose will not disclose your sensitive information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act or GDPR, or to comply with any other regulatory requirement.

Splose will immediately remove your personal information from its database if requested by you. Splose will do this in accordance with their policy on destroying personal information (see Destruction of Information), in order to keep your information secure.

Where possible, Splose will give you the option of not identifying yourself or of using a pseudonym. Splose may not always be able to interact with you in this manner, especially where it is required by law to identify you before providing certain information. In general, Splose will not be able to assist you anonymously or where you are using a pseudonym when it is impractical or we are required or authorised by law or a court/tribunal order to deal with you personally.

Direct Marketing

By accepting the Conditions of the Website and providing us with your personal information, you consent to us sending you direct marketing communications by any of the methods listed above (see Purposes for Collecting, Holding, Using and Disclosing your Personal Information). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt out of receiving marketing communications from us by contacting us (see contact details below) or by using opt out facilities provided in the marketing communications, and we will then ensure that your name is removed from our mailing list.

Please note that by opting out of receiving marketing communications, you may still receive communications from us (such as invoices and notices) in relation to the products and services you have purchased from us.

Disclosure to Overseas Recipients

We may disclose your personal information to our related bodies corporate, third party suppliers, service providers, government and quasi-governmental organisations, prospective purchasers of part or whole of our business and stock exchanges located overseas for some of the purposes listed above (see Disclosure of Personal Information).

We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

Disclosure of Personal Information

Splose may disclose your personal information to:

  • our employees, related bodies corporate, contractors or service providers for the purposes of operating our Website 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;
  • suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;
  • government and regulatory bodies and law enforcement agencies; and
  • any other organisation for any authorised purpose with your express consent, including your insurers and your solicitors.

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.

We are not responsible for the privacy policies of any third party, and we accept no liability on behalf of any third party. Third parties are responsible for informing you about their own privacy practices. The third party providers (i.e. the subprocessors) that are used by Splose are listed at https://support.splose.com/en/articles/4317944-subprocessors-list.

Except as set out in this Privacy Policy, Splose will only disclose personal information with your permission or as required or allowed to do so by law.

Access to Personal Information

We require accurate personal information about you to ensure you receive the best possible service from Splose.

You will be able to access personal information that Splose holds about you if it can be readily retrieved, subject to some exceptions allowed by law. Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you).

To request access to your personal information, please contact Splose in writing. We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. In these instances, we will provide written reasons for any refusal.

Updating Personal Details

We take reasonable steps to ensure that your personal information is up-to-date whenever we collect it or use it. This may include, for example, using data obtained from third parties to verify the accuracy of your personal information.

If you find that current personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will take reasonable steps to correct it.

Inability to Collect Personal Information

If you do not provide us with the personal information described above (see Collection of Personal Information), some or all of the following may happen:

  • we may not be able to provide the requested products or Services to you, either to the same standard as if we did have access to personal information, or at all;
  • we may not be able to process any third party discounts or benefits;
  • we may not be able to notify you of any updates to our Privacy Policy and/or Terms and Conditions;
  • we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions; or
  • we may be unable to tailor the content of our Website to your preferences and your experience of our Website may not be as enjoyable or useful.
Secure Storage of Personal Information

We take reasonable steps to ensure we protect any personal information that we hold from misuse, loss and unauthorised access, modification and disclosure.

Your personal information may be stored in hard copy documents and electronically.

We maintain physical and electronic security over our paper and electronic data storage. We also maintain computer and network security. For example, we use firewalls (security measures for the Internet) and other systems such as user identifiers and passwords to control access to computer systems.

Although we take reasonable steps to maintain the security of our Internet connections, for reasons outside of our control, information transmitted to us over the Internet may not be absolutely secure. Splose assumes no responsibility for disclosure of data due to errors in transmission.

If we become aware that any of your personal information has been accessed by an unauthorised party (Data Breach), we will notify you of the Data Breach within 72 hours of us becoming aware of such breach.

Destruction of Information

If the personal information we collect is no longer needed for any purposes and we are not required by law to retain it, Splose has procedures in place to ensure that any document or record containing your personal or health information is disposed of in a manner that preserves your privacy.

Splose will immediately remove your personal information from its database if requested by you.

Third Party Websites

Our Website may contain links to other mobile applications or websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party mobile applications or websites and we are not responsible, or in any way liable, for the privacy policies or the content of any third party mobile applications or websites. Third party mobile applications or websites are responsible for informing you about their own privacy practices.

We take precautions to protect your personal information collected through http://www.splose.com  but in the event that our system is infiltrated by unauthorised third parties, we will not be liable for any resulting misuse of personal information.

General Data Protection Regulations

If you are an individual residing in the European Union (EU), Splose will comply with the EU data protection regulations contained in the GDPR which provides a framework for the fair and transparent collection and use of personal information.

Any data collected by us will be collected with your express consent, and will only ever be collected for a specific purpose (which shall not be excessive). We use and process your personal information as a “Processor” and/or (if applicable) as a “Controller”, as defined in the GDPR.

We only collect and process your personal information where, it is necessary:

  • for our legitimate interests;
  • to maintain your health, safety and wellbeing, and in medical circumstances;
  • to undertake a task that is in the public interest and has a clear legal basis;
  • to provide products and/or Services, and to send communications, to you;
  • to comply with the terms of a contract and/or fulfil other legal obligations; and
  • for any other purpose listed above (see Purposes for Collecting, Holding, Using and Disclosing your Personal Information), provided such purpose does not contravene the GDPR.

We will not collect or process personal information known as “Sensitive Personal Information” under the GDPR (such as personal information regarding your ethnicity, or sexual orientation) without your consent, unless such personal information is otherwise collected pursuant to the GDPR.

We do not collect or process personal information of children (i.e. individuals aged younger than 16). If you are under the age of 16, you need the consent of your parent and/or legal guardian before you, and you must not without your parent’s and/or legal guardian’s consent, provide your personal information to us.

If you are an individual residing in the EU, in addition to any other right provided in this Privacy Policy (that does not contravene the GDPR), you have the following rights:

  • to gain access to (at your request) your personal information - if you would like to gain access to your personal information, please contact us and we will provide you with access to such information at any time. However, there may be certain instances where we cannot grant you access to the personal information we hold, such as where it may interfere with the privacy of others;
  • to be provided information regarding how your personal information is used by us – we have provided a comprehensive explanation of how your personal information is used in this Privacy Policy (see above and Purposes for Collecting, Holding, Using and Disclosing your Personal Information);
  • to update, correct and amend (at your request) any or all of your personal information where such personal information is incomplete or inaccurate – if any personal information you have provided to us is inaccurate or incomplete, please let us know and we will promptly correct it;
  • to be forgotten and (at your request) have your personal information deleted from our records – if you do not want us to use your personal information anymore, where we no longer need to use the personal information, you may request we delete your personal information and we will delete that personal information from our records. If requested by you, we will delete such personal information in accordance with our policy of destroying information (see Destruction of Information);
  • to restrict our processing of your personal information – if you would like us to stop processing any or all of your personal information, you can stop us from processing your personal information by notifying us in writing of what personal information you would like to restrict us from using and why;
  • to (for your own purposes) use your personal information – any personal information that you provide to us may be reused and retained by you;
  • to object (under specific circumstances) to our use of your personal information – where you do not want us to use your personal information for a certain purpose (set out in this Privacy Policy) you may request we do not use your personal information in such way by contact us and objecting to such use. If you object to our use of your personal information for a direct marketing purposes, we will immediately stop using your personal information. Where you object to our use of your personal information for all other reasons, unless we are able to provide “legitimate grounds” for using your personal information, we will no longer use your personal information for the purposes you object to;
  • to object to us profiling and engaging in automated decision making – you may request that we do not engage in automated processing (i.e. processing solely by a computer without human intervention) of your personal information to evaluate certain personal aspects relating to you;
  • to have your information protected in a safe and secure manner – we will retain your personal information in a confidential manner, whilst ensuring the personal information remains available for you at any time (at your request); and
  • to have your personal information transferred to recipients only under specific circumstances – we will only transfer (without your express consent) your personal information to recipients that are permitted under the GDPR. In all other respects, we will obtain your consent before transferring your personal information to third-parties.

To the extent of any inconsistency between the terms of this section “General Data Protection Regulations” and any other term of this Privacy Policy, the terms of this section and any term of the GDPR shall prevail (where you are residing in the EU).

Indemnity

Whilst we will use all reasonable endeavours to safeguard your personal information, we cannot guarantee that your personal information will be protected against unauthorised access, misuse or disclosure. We do not accept any liability for the improper actions of unauthorised third parties. 

Splose also assumes no responsibility or liability for third parties such as advertisers or other entities who utilise banner advertisements and links from our Website. If you click through a banner, advertisement, or link and submit your information to a third party, you will be subject to the privacy policies of that third party.

Splose ensures that all employees and contractors are bound by a confidentiality agreement requiring that they do not use or disclose your personal information in a manner contrary to this Privacy Policy.

We retain your personal information in line with relevant legislation and for as long as the information is relevant to our business purposes as set out above (see Collection of Personal Information) or until you request that we remove the information by contacting Splose. 

You agree to defend, indemnify, and hold harmless Splose, our officers, directors, employees, agents, subcontractors, licensors, and suppliers, from and against all claims, actions, demands, liabilities and settlements, arising in connection with your use of the Website or your breach of the Terms and Conditions.

Changes to Privacy Policy

All information which is held by Splose is governed by the latest version of this Privacy Policy at all times. Splose may change this Privacy Policy at any time without notice. We will let you know as soon as reasonably practicable after our Privacy Policy has changed.

Complaints

If you believe that your privacy has been breached, please contact us immediately using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint and undertake our own thorough investigation into such breach. We will attempt to confirm as appropriate and necessary with you, your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will investigate your complaint and advise you of the outcome of our investigations in writing.

If you feel we have failed to deal with your complaint in a satisfactory manner, you can make a complaint about the handling of your personal information by Splose to the Office of the Australian Information Commissioner (Australia) (https://www.oaic.gov.au), or if you are based in the EU, the relevant Data Protection Authority of your country, as accessible by contacting the European Commission (https://www.ec.europa.eu).

Contact Us

If you have any questions about this Privacy Policy, any concerns or a complaint relating to your personal information, please contact us at:

Splose Pty Ltd
Address: Suite 24, Stone & Chalk, Lot Fourteen, Adelaide SA 5000
Email: support@splose.com

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