Easyserv Pty Ltd ACN 667 230 962 (“Easyserv”) (“we”, “us” or the “Company”) is committed to privacy protection. Easyserv, we understand the importance of keeping personal information private and secure. This privacy policy (“Privacy Policy”) describes generally how we collect, use and protect personal information and safeguard privacy. If you would like more information, please don’t hesitate to contact us.

This Privacy Policy applies when you visit our websites, internet sites, mobile sites, our platforms, applications and any of our content on social media sites (Sites) on any computer, mobile phone, tablet, console, or device (Device) for the purpose of receiving our services (Services). This Privacy Policy forms part of, and is subject to the provisions of, our Terms of Use https://easyserv.au/terms.

The privacy of your personal information is really important to us so please take the time to read this Privacy Policy carefully.

We care about your privacy.

We will never rent, trade or sell your email address to anyone.

We will never publicly display your email address or other personal details that identify you.

Consent

Your consent to this Privacy Policy is the legal basis upon which we can collect, use, store, process and disclose your personal information.

You acknowledge and agree that:

• by submitting personal information to us via, or by using, accessing or browsing, our Sites on any Device, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy
• you have had a sufficient opportunity to access and review this Privacy Policy and you have read this Privacy Policy (in its entirety) and agreed to its terms; and
• you are 18 years of age or older.
  
  

If you do not wish to provide personal information to us, then you are not obliged to do so. However, please be aware that you will be unable to register for and access our Sites without providing the minimum amount of personal information required in the registration process. You cannot register for our Sites without agreeing to be bound by this Privacy Policy and Terms of Use.

Privacy Legislation

We will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Cth) (“Privacy Act”) as amended from time to time, as well as the EU General Data Protection Regulation (EU) 2016/679 (GDPR) (in circumstances where the GDPR applies to us). The Privacy Act lays down 13 key principles in relation to the collection and treatment of personal information, which are called the “Australian Privacy Principles”.

What personal information we collect

Personal information is defined in the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

We only collect personal information you give us directly, or which is collected automatically as part of your activities with us (including usage data or cookies on our Sites).

The personal information that we collect includes:

• identifying information, including your name, date of birth, contact details including your email, residential address, telephone/mobile/fax numbers and billing address,
• transactional information, including information you provide as part of a transaction with us or that is generated as a result of that transaction;
• financial information, including payment details, credit card numbers or bank details;
• information we are required or authorised to collect and process under law to identify you or verify information you have provided;
• usage information, including data about your interaction with our Sites through your Devices;
• computer and connection information such as page views, traffic, URLs, IP address and web log information

Why we collect personal information

We will only use your personal information for the purpose which it was collected or as otherwise in accordance with this Privacy Policy.  Purposes for collecting personal information include, but are not limited to:

• providing you with use of our Sites;
• supplying the Services to you;
• ensuring the security of our Sites and maintaining back-ups of our database(s);
• processing payments you have authorised;
• conduct appropriate checks for credit-worthiness and for fraud;
• detect any misuse of, or fraudulent activities involving our Sites;
• improving and optimising our Services, business and our users’ experience;
• sending you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• sending you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting. You may opt out of receiving these direct marketing communications at any time. Our electronic marketing activities will comply with the requirements of the Spam Act 2003 (Cth);
• complying with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
• considering your employment application; and
• for any other purposes identified at the time of collecting your personal information.
  
  

In addition, you permit us to use your personal information:

• where you have consented to the use or disclosure;
• where we reasonably believe that use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone’s health or safety or the public’s health or safety;
• where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
• where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
• where we reasonably believe that use or disclosure is necessary for the prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, or conduct of, proceedings before any court or tribunal (or the implementation of orders of a court or tribunal or on behalf of an enforcement body);
• to develop and improve our (and our related entities’) business, products and Services;
• to involve you in market research, gauging customer satisfaction and seeking feedback; and
• for our internal accounting and administration.

How we may collect your personal information

We may collect personal information that you provide to us about yourself when you:

• use our Sites, including (without limitation) when you:
• add reviews, forum or chat room messages or comments in any elements of our Sites that permit user-generated content;
• register for access to premium content or request certain premium features; or
• complete an online contact form to contact us;
• provide information to us by telephone or through marketing or competition application forms; or
• send us an email or other communication.

IP addresses

Our Sites may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, our Sites.

Cookies

Our Sites use “cookies” to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at our Sites: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the “Cookies” folder on your computer and remains in that folder after you close your browser and may be used by your browser on subsequent visits to our Sites. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Sites.

Why we use cookies

Our Sites use cookies in order to:

• remember your preferences for using our Sites;
• show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, subscribed to newsletters or email or other subscription services); and
• remember details of data that you choose to submit to us (e.g., through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).
  
  

Many of these cookies are removed or cleared when you log out, but some may remain so that your preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies through our Sites. For example:

• Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on our Sites and the pages that they visit;
• Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
• third party social media applications (e.g., Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in our Sites.

When we may disclose your personal information

For the purposes set out above, we may disclose your personal information to third parties. Your personal information disclosed to these organisations only in relation to our Sites, and we take reasonable steps to ensure that these third party recipients are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These third parties may carry out or provide:

• client enquiries;
• mailing systems;
• billing and debt-recovery functions;
• information technology services;
• marketing, telemarketing and sales services;
• market research; and
• website usage analysis.
  
  

In addition, we may disclose your personal information to:

• your authorised representatives or legal advisers (when requested by you to do so);
• credit-reporting and fraud-checking agencies;
• suppliers of IT based solutions that assist us in providing products and services to you;
• credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing); and
• our external business advisers; and
• government and regulatory authorities and other organisations, as required or authorised by law.
  
  

Without your consent, we will not disclose your personal information to any third party (except for those described above), unless such disclosure is required by local data protection laws or the GDPR and/or where we reasonably believe that it is necessary to lessen or prevent a threat to life, health or safety or for action to be undertaken by an enforcement body, or where allowed to do so in accordance with the local data protection laws.

At all times, the third parties that we disclose your personal information to:

• are required to provide GDPR compliant services (if they are subject to comply with the GDPR);
• must take reasonable steps, to our satisfaction, to ensure that personal information disclosed by us is protected against misuse, interference, loss and unauthorized access, modification and disclosure;
• must ensure that each of its employees who access, use or disclose personal information are aware of and comply with the obligations under this Privacy Policy when they are accessing, using or disclosing the personal information; and
• must, if they become aware of any misuse, interference, loss, or unauthorized access, modification or disclosure of personal information disclosed by us, immediately notify us.
  
  

To the maximum extent provided by the relevant laws, we are not responsible or liable for the protection and privacy of any personal information which is provided to third parties. This means that, where your personal information has been disclosed, you accept and agree that the disclosed personal information will be held by third parties and may be used by them in accordance with the Privacy Act and any privacy policy they may have and in such circumstances, the third party recipient will be solely responsible for their use of this personal information.

Contacting us about privacy

If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us by email to privacy@easyserv.au.

Access to your personal information

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:

• be unlawful (e.g., where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
• have an unreasonable impact on another person’s privacy; or
• prejudice an investigation of unlawful activity.
  
  

We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.

If we refuse to give you access, we will provide you with reasons for our refusal.

Correcting your personal information

We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

Where applicable under the GDPR, we will honour your right to request access to, or modification or deletion of, your personal information. We may have the right to withhold that access or refuse to modify or erase your personal information under applicable laws but will give you reasons if we do so.

Storage and security of your personal information

We are committed to maintaining the confidentiality of the information that you provide us, and we will take all reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form.

Data that we collect about you may be stored or otherwise processed by third party services with data centres based outside the EU, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc and online relationship management tools. 

We require that all third parties that act as “data processors” for us provide sufficient guarantees and implement appropriate technical and organisational measures to secure your data, and that they only process personal data for specified purposes and commit themselves to confidentiality. We will only use third parties located outside of Australia who have represented to us that they are GDPR compliant.

Firewalls, anti-virus software and email filters, as well as passwords, protect all of our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information. However, electronic transmission of information is never completely secure or error-free. As a result, while we strive to protect users’ personal information, we cannot ensure or warrant the security of any information electronically transmitted by a user, and users provide their personal information at their own risk. To the maximum extent provided by the relevant laws, we are not responsible or liable for the electronic transmission of personal information to us or to third parties.

We will only use, process or store personal information for as long as required by the purpose it has been collected, including where such purpose relates to our legitimate interest, and for a longer period where you have given consent to such processing, as long as such consent is not withdrawn. We may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements.  At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning).  In some circumstances, you can ask us to delete your data.

Third party websites

You may click-through to third party websites from our Sites, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to our Sites only and we assume no responsibility for the content of any third party websites.

Re-marketing

We may use the Google AdWords and/or Facebook re-marketing services to advertise on third party websites to previous visitors to our Sites based upon their activity on our Sites. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of your personal Google and/or Facebook information is reported to us.

You can set preferences for how Google advertises to you using the Google Ads Settings page. Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time by publishing a new version on our Site. By continuing to use our website or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time.

Further Information

If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Australian Information Commissioner’s website (see https://www.oaic.gov.au/).

Effective: 02 May 2023