IncludeChange Pty Ltd A.C.N.617 731 763 (we, us, our, or IncludeChange) recognises and values the protection of your personal information.
- information we collect and hold about you;
- our use and disclosure of your personal information;
- the legal basis we rely upon to process your personal information;
- your rights over your personal information;
- the security of personal information;
- our disposal of personal information, when no longer needed;
- overseas transfer of personal information;
- privacy relating to persons aged under 16 years; and
- contacting us with any questions or concerns that you may have.
Information we collect and hold
Wherever possible, you can elect to remain anonymous, or use a pseudonym, in interacting with us (for example, when making an enquiry).
From time to time, we may ask you to supply personal information such as your name, address, date of birth, telephone number, e-mail address or cookies and usage data. However, under no circumstances will we request any information from you that may disclose your:
- political, religious or philosophical opinions, beliefs, associations or affiliations;
- health and sexuality;
- racial or ethnic origin;
- membership of a trade union, or a professional or trade association; or
- criminal records.
We may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the types and quality of services offered to you, and the manner in which those services are offered to you.
How we collect your personal information
We use various methods to collect personal information about you, including:
Direct interactions – you may provide us with your personal information by filling in forms or by corresponding with us, in various ways.
Use and disclosure of your personal information
When we hold your personal information, it will be used for the following primary purposes:
- to ensure the proper functioning of our Website;
- to ensure the proper functioning of our business; and
- to assist us with our auditing, marketing, planning, billing, product development and research requirements.
We will not use or disclose (or permit the use or disclosure of) information that could be used to identify you in any circumstances, except:
- to ensure the proper functioning of our business and the Website;
- to communicate promotional offers and special events to you;
- where the law requires us, or authorises us, or a third party holding data on our behalf, to do so; or
- where you have given express consent to us for a prescribed purpose.
We will not sell, distribute, rent, licence, disclose, share or pass your personal information on to any third parties, other than those that are contracted to us, to keep the information confidential.
Should a third party approach us, with a demand to access your personal information, we will take reasonable steps to redirect the third party to request the information directly from you, wherever it is lawful and reasonable for us to do so.
If we are compelled to disclose your personal information, to a third party, we will take reasonable steps to notify you of this in advance, provided that it is lawful and reasonable for us to do so.
Legal basis we rely upon to process your personal information
The GDPR sets out numerous grounds upon which we may lawfully collect and process your personal information, including:
- where you have provided us with your consent to do so;
- where we need to perform a contract with you;
- where we are required to comply with the law;
- for payment processing purposes; and
- when processing of your personal information is in our legitimate interests and it’s not overridden by your rights.
We can collect and process your data if we have your consent. In many circumstances, if we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent, at any time.
In many circumstances, we require your personal information to comply with contractual obligations. For example, we collect your identity and contact information when we provide you with our goods or services. If you are unable to provide such information to us, we may not be able to perform the contract we have with you or your business, or enter into a contract with you or your business.
We may need to collect and process your personal data, if the law requires us to. If you are unable to provide such information to us, we may not be able to perform the contract we have with you or your business, or enter into a contract with you or your business.
We will often require your personal information to pursue our legitimate interests, in a way which might reasonably be expected as part of running our business and which does not materially impact upon your rights, freedoms or interests. For example, it may be in our legitimate interests to use your personal information for marketing purposes to assist us with the growth of our business.
Please email us if you require details of the specific legal ground we are relying on to process your personal information.
Your rights over your personal information
You have a number of rights with respect to the personal information that we hold about you. These rights are subject to certain exemptions and differ across the jurisdictions, in which we may operate.
Request access to the personal information that we hold about you
Subject to any applicable exceptions, we will provide you with a copy of your personal information, within the timeframes set out in relevant legislation. If you reside within the EU, then we will do this at no charge, in accordance with the GDPR.
Right to rectification
You have the right to have us rectify any inaccurate information that we hold about you.
Right to erasure
You will, in certain circumstances, have the right to request that we delete or remove your personal information. Whenever you have given us your consent to use your personal information, you have the right to change your mind, at any time, and withdraw that consent. In cases where we are processing your personal information on the basis of our legitimate interests, you can ask us to stop processing your information, for reasons connected to your individual situation. We must then do so, unless we believe that we have a legitimate reason to continue processing your personal information.
Right to data portability
You will, in certain circumstances, have the right to obtain your personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer your personal information, to a third party, without any hindrance from us.
Right to object
You will, in certain circumstances, have the right to object to our processing of your personal information. Where personal information is being processed for direct marketing purposes, you have a right to object at any time
Right to withdraw consent
You have the right to withdraw your consent, at any time, for us to process your personal information. We may ask you to verify your identity before responding to such requests.
Rights in relation to automated decision-making and profiling
You will, in certain circumstances, have a right not to be subject to a decision that is based on automated processing, where the decision will produce a legal effect, or a similarly significant effect on you.
To protect the confidentiality of your personal information, we will require you to verify your identity before proceeding with any request. If you have authorised a third party to submit a request to us on your behalf, then we will ask them to prove they have obtained your permission to act on your behalf.
Security of personal information
We may store personal information, both electronically, and in hard-copy form. We are committed to keeping your personal information secure, regardless of the format in which we hold it and we take all reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure. However, you use our Website at your own risk and we accept no responsibility, whether we are deemed to have been negligent or not, in the event of a security that affects your privacy.
Overseas transfer of personal information
Disposal of personal information not required
If we hold personal information about you, and we do not need that information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify that information, unless we are otherwise prevented from doing so by law.
Cookies data and online tracking technologies
Privacy relating to persons under the age of 16 years
We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are under 16 years of age, then your parent or guardian must provide us with consent for us to process your personal information.
Contacting us and complaints