Last updated 14 August 2022
1.1 Our commitment to You
We at AFFIXCON (as defined below in section 1.2 below) recognize the importance of your privacy and understand the concerns you may have regarding the security of your Personal Information, and we commit to protecting the privacy of the Personal Information we may hold.
We recognize that we are bound by in-country and international privacy, disclosure, and data transfer legislation which is not limited to but contains the Australian Privacy Act 1988, the General Data Protection Regulation (EU GDPR), and The California Consumer Privacy Act of 2018 (CCPA).
AFFIXCON, we, us or our refers to AFFIXCON Pty Ltd (ABN: 87 635 466 670). “you” or “user” means you and includes everyone who deals with AFFIXCON as a customer, visitor, employee, contractor, Data Contributor or Contributor Subject.
This document explains clearly who we hold Personal Information on, how we collect it, how we use it, and how to contact us.
2 WEBSITE CONTACTS
2.1 Personal information we collect:
We collect personal information from the website in the form of cookies and IP addresses.
2.1.1 Website Analysis and Protection using IP addresses and Cookies
We collect information on your use of our website via a session cookie and IP address to:
(a) Assess your legitimacy to visit our website.
(b) Confirm your action on our website is appropriate.
(c) Improve our website usability.
Your visit information consists of:
(a) The date and time of your visit
(b) The pages viewed on the website
(c) IP address
You are a Client Contact if you interact with us to consumer our services under contract or as a prospective purchaser.
3.1 Personal information we collect:
We collect personal information from correspondence with you:
3.1.1 Sales Contacts
We collect Personal information about you from our direct contact with you in order to facilitate a sales contract.
The information collected can include:
(a) Company Details
(b) Company Representative
(c) Representative contact telephone number
(d) Representative contact email
(e) Representative contact address
(f) Any other information applicable or required to facilitate the contract sale
We collect your Personal information to:
(a) Facilitate the contract sale
(b) Contact you in respect of the management of the contract sale
4 PUBLIC INFORMATION
We collect, compile and hold personal information sourced from
(a) Published directories or lists
(b) Public domain data such as ABS statistics
5 CONTRIBUTOR LEADS
We do not collect data directly from the consumer (other than those described above). We contract with Contributors to utilize their opted-in consumer data assets.
Our Contributors are sourced from three types of industry-leading data generating organizations, these include online mobile device-driven location data, offline opt-in lead generation data, and offline attribute data at the address and person level.
To guarantee compliance with Privacy Standards all Personal Information collected and supplied to us by our Contributors must be done so with clear and compliant privacy notices and opt-in/out management that allow for collection, use, and distribution to 3rd parties. Noncompliant data that is identified by us is suppressed and Contributors are suspended under audit.
We require from its Contributors that they warrant:
(a) The Consumer records are collected in compliance with the Privacy Legislation in the country where the data is collected and from the contrary, the data is collected.
(b) The Consumer consented / opted-in such that their details can be utilized to fulfil Our Use Cases.
(c) The Consumer consented / opted-in such that their details can be provided to third-party organizations downstream.
(d) The Consumer consented / opted-in such that their details can be provided to Third Party Organizations outside of the country from which the data was sourced and collected.
(e) The Contributors have a robust and effective Consumer opt-out process from the Consumer and to and from us
(f) The Consumer has been informed of the Contributor opt-out process.
(g) The Contributors have a data breach policy.
(h) The Contributors consent to Our Privacy compliance attestation audit.
6 PERSONAL INFORMATION DISCLOSURE
We do not share any of your personal information with third-parties unless you are a Contributor Lead. In addition, any personal information shared is limited to the purpose for which it is acquired and under the consent terms of that acquisition.
Additionally, any disclosure is also subject to our information security controls set out in our Information Security Policy, data processing agreements, and relevant privacy laws.
It should be noted that we may be required to disclose Personal Information by law or enforceable request by a regulatory body.
7 INTERNATIONAL DATA TRANSFERS
We are an international company, as such while we do not hold EU or US data we comply with global standards on the international transfer of data.
We do not hold or transfer Personal Information in or through countries that do not have adequate measures in place to protect the Personal Information.
8 PERSONAL DATA ACCESS
8.1 Who to contact
8.2 Your Request
You may request any of the following:
How and where your Personal Information was obtained
(a) What Personal Information do we hold
(b) To change the consent of use of your personal information – including its suppression and deletion
(c) To correct your Personal Information
There is no charge for interaction with us.
8.3 Your Request Refusal
We may refuse your request if we are not able to appropriately identify you are the person
We appreciate your patience with this process which ensures we are talking to the correct person and not disclosing Personal Information to the wrong person.
8.4 Right to Lodge a Complaint
Your interaction with us does not limit your right to lodge a complaint with the relevant data protection or supervisory authority in your country. We will provide you with appropriate location contacts on request.
8.5 Rights of Anonymity
When legally possible we will ensure you can communicate with us anonymously if you so desire. It should be noted, however, that we may need to obtain Personal Information from you to verify we are talking to the person who is asking for personal information disclosure from us.
9 RETENTION, DISPOSAL, OR DESTRUCTION OF PERSONAL INFORMATION
We collect, use, and store Personal Information only for the time that it fulfills the purpose for which it was collected and/or Consented. Once such Personal Information falls outside these boundaries, we dispose of such data under our Information Security Management System policies.
No data is collected or maintained for people under the age of 18 years. Significant resources are dedicated to ensuring this is the case through Contributor attestation, audits, and sample testing.
12 BREACH OF POLICY
We will take all necessary measures to remedy any breach of this policy.