Privacy Policy

Pointo Pty Ltd

  1. We respect your privacy

1.1. Pointo Pty Ltd respects your right to privacy and is committed to safeguarding

the privacy of our customers and website visitors. This policy sets out how we

collect and treat your personal information.

1.2. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988

(Cth) and to the extent applicable, the EU General Data Protection Regulation

(GDPR).

1.3. “Personal information” is information we hold which is identifiable as being about

you. This includes information such as your name, email address, identification

number, or any other type of information that can reasonably identify an

individual, either directly or indirectly.

1.4. You may contact us in writing at Level 13/ 200 Queen street, Melbourne,

Victoria, 3000 for further information about this Privacy Policy.

  1. What personal information is collected

2.1. Pointo Pty Ltd will, from time to time, receive and store personal information you

submit to our website, provided to us directly or given to us in other forms.

2.2. You may provide basic information such as your name, phone number, address

and email address to enable us to send you information, provide updates and

process your product or service order.

2.3. We may collect additional information at other times, including but not limited to,

when you provide feedback, when you provide information about your personal

or business affairs, change your content or email preference, respond to surveys

and/or promotions, provide financial or credit card information, or communicate

with our customer support.

2.4. Additionally, we may also collect any other information you provide while

interacting with us.

  1. How we collect your personal information

3.1. Pointo Pty Ltd collects personal information from you in a variety of ways,

including when you interact with us electronically or in person, when you access

our website and when we engage in business activities with you. We may receive

personal information from third parties. If we do, we will protect it as set out in

this Privacy Policy.

3.2. By providing us with personal information, you consent to the supply of that

information subject to the terms of this Privacy Policy.

  1. How we use your personal information

4.1. Pointo Pty Ltd may use personal information collected from you to provide you

with information about our products or services. We may also make you aware of

If you withhold your personal information, it may not be possible for us to provide you

with our products and services or for you to fully access our website.

new and additional products, services and opportunities available to you.

4.2. Pointo Pty Ltd will use personal information only for the purposes that you

consent to. This may include to:

(a) provide you with products and services during the usual course of our business

activities;

(b) administer our business activities;

(c) manage, research and develop our products and services;

(d) provide you with information about our products and services;

(e) communicate with you by a variety of measures including, but not limited to, by

telephone, email, sms or mail; and

(f) investigate any complaints.

4.3. We may disclose your personal information to comply with a legal requirement,

such as a law, regulation, court order, subpoena, warrant, legal proceedings or

in response to a law enforcement agency request.

4.4. If there is a change of control in our business or a sale or transfer of business

assets, we reserve the right to transfer to the extent permissible at law our user

databases, together with any personal information and non-personal information

contained in those databases.

  1. Disclosure of your personal information

5.1. Pointo Pty Ltd may disclose your personal information to any of our employees,

officers, insurers, professional advisers, agents, suppliers or subcontractors

insofar as reasonably necessary for the purposes set out in this privacy policy.

5.2. If we do disclose your personal information to a third party, we will protect it in

accordance with this privacy policy.

  1. General Data Protection Regulation (GDPR) for the European Union (EU)

6.1. Pointo Pty Ltd will comply with the principles of data protection set out in the

GDPR for the purpose of fairness, transparency and lawful data collection and

use.

6.2. We process your personal information as a Processor and/or to the extent that

we are a Controller as defined in the GDPR.

6.3. We must establish a lawful basis for processing your personal information. The

legal basis for which we collect your personal information depends on the data

that we collect and how we use it.

6.4. We will only collect your personal information with your express consent for a

specific purpose and any data collected will be to the extent necessary and not

excessive for its purpose. We will keep your data safe and secure.

6.5. We will also process your personal information if it is necessary for our legitimate

interests, or to fulfil a contractual or legal obligation.

6.6. We process your personal information if it is necessary to protect your life or in a

medical situation, it is necessary to carry out a public function, a task of public

interest or if the function has a clear basis in law.

6.7. We do not collect or process any personal information from you that is

considered “Sensitive Personal Information” under the GDPR, such as personal

information relating to your sexual orientation or ethnic origin unless we have

obtained your explicit consent, or if it is being collected subject to and in

accordance with the GDPR.

6.8. You must not provide us with your personal information if you are under the age

of 16 without the consent of your parent or someone who has parental authority

for you. We do not knowingly collect or process the personal information of

children.

  1. Your rights under the GDPR

7.1. If you are an individual residing in the EU, you have certain rights as to how your

personal information is obtained and used. Pointo Pty Ltd complies with your

rights under the GDPR as to how your personal information is used and

controlled if you are an individual residing in the EU

7.2. Except as otherwise provided in the GDPR, you have the following rights:

(a) to be informed how your personal information is being used;

(b) access your personal information (we will provide you with a free copy of it);

(c) to correct your personal information if it is inaccurate or incomplete;

(d) to delete your personal information (also known as “the right to be forgotten”);

(e) to restrict processing of your personal information;

(f) to retain and reuse your personal information for your own purposes;

(g) to object to your personal information being used; and

(h) to object against automated decision making and profiling.

7.3. Please contact us at any time to exercise your rights under the GDPR at the

contact details in this Privacy Policy.

7.4. We may ask you to verify your identity before acting on any of your requests.

  1. Hosting and International Data Transfers

8.1. Information that we collect may from time to time be stored, processed in or

transferred between parties or sites located in countries outside of Australia.

These may include, but are not limited to Australia.

8.2. We and our other group companies have offices and/or facilities in Australia.

Transfers to each of these countries will be protected by appropriate safeguards,

these include one or more of the following: the use of standard data protection

clauses adopted or approved by the European Commission which you can

obtain from the European Commission Website; the use of binding corporate

rules, a copy of which you can obtain from Pointo Pty Ltd’s Data Protection

Officer.

8.3. The hosting facilities for our website are situated in Australia. Transfers to each

of these Countries will be protected by appropriate safeguards, these include

one or more of the following: the use of standard data protection clauses

adopted or approved by the European Commission which you can obtain from

the European Commission Website; the use of binding corporate rules, a copy of

which you can obtain from Pointo Pty Ltd’s Data Protection Officer.

8.4. Our Suppliers and Contractors are situated in Australia. Transfers to each of

these Countries will be protected by appropriate safeguards, these include one

or more of the following: the use of standard data protection clauses adopted or

approved by the European Commission which you can obtain from the European

Commission Website; the use of binding corporate rules, a copy of which you

can obtain from Pointo Pty Ltd’s Data Protection Officer.

8.5. You acknowledge that personal data that you submit for publication through our

website or services may be available, via the internet, around the world. We

cannot prevent the use (or misuse) of such personal data by others.

  1. Security of your personal information

9.1. Pointo Pty Ltd is committed to ensuring that the information you provide to us is

secure. In order to prevent unauthorised access or disclosure, we have put in

place suitable physical, electronic and managerial procedures to safeguard and

secure information and protect it from misuse, interference, loss and

unauthorised access, modification and disclosure.

9.2. Where we employ data processors to process personal information on our

behalf, we only do so on the basis that such data processors comply with the

requirements under the GDPR and that have adequate technical measures in

place to protect personal information against unauthorised use, loss and theft.

9.3. The transmission and exchange of information is carried out at your own risk.

We cannot guarantee the security of any information that you transmit to us, or

receive from us. Although we take measures to safeguard against unauthorised

disclosures of information, we cannot assure you that personal information that

we collect will not be disclosed in a manner that is inconsistent with this Privacy

Policy.

  1. Access to your personal information

10.1. You may request details of personal information that we hold about you in

accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent

applicable the EU GDPR. If you would like a copy of the information which we

hold about you or believe that any information we hold on you is inaccurate, out

of date, incomplete, irrelevant or misleading, please email us at

info@pointo.com.au.

10.2. We reserve the right to refuse to provide you with information that we hold about

you, in certain circumstances set out in the Privacy Act or any other applicable

law.

  1. Complaints about privacy

11.1. If you have any complaints about our privacy practices, please feel free to send

in details of your complaints to info@pointo.com.au. We take complaints very

seriously and will respond shortly after receiving written notice of your complaint.

  1. Changes to Privacy Policy

12.1. Please be aware that we may change this Privacy Policy in the future. We may

13th September 2018

modify this Policy at any time, in our sole discretion and all modifications will be

effective immediately upon our posting of the modifications on our website or

notice board. Please check back from time to time to review our Privacy Policy.

  1. Website

13.1. When you visit our website

When you come to our website (pointo.com.au), we may collect certain

information such as browser type, operating system, website visited immediately

before coming to our site, etc. This information is used in an aggregated manner

to analyse how people use our site, such that we can improve our service.

13.2. Cookies

We may from time to time use cookies on our website. Cookies are very small

files which a website uses to identify you when you come back to the site and to

store details about your use of the site. Cookies are not malicious programs that

access or damage your computer. Most web browsers automatically accept

cookies but you can choose to reject cookies by changing your browser settings.

However, this may prevent you from taking full advantage of our website. Our

website may from time to time use cookies to analyses website traffic and help

us provide a better website visitor experience. In addition, cookies may be used

to serve relevant ads to website visitors through third party services such as

Google AdWords. These ads may appear on this website or other websites you

visit.

13.3. Third party sites

Our site may from time to time have links to other websites not owned or

controlled by us. These links are meant for your convenience only. Links to third

party websites do not constitute sponsorship or endorsement or approval of

these websites. Please be aware that Pointo Pty Ltd is not responsible for the

privacy practises of other such websites. We encourage our users to be aware,

when they leave our website, to read the privacy statements of each and every

website that collects personal identifiable information.