Spacetalk Privacy Policy

Spacetalk Privacy Policy

We are Spacetalk Ltd (ACN 091 351 530), Spacetalk Holdings Pty Ltd (ACN 606 733 804), Spacetalk USA Pty Ltd (ACN 45 606 734 598) its UK subsidiary, SPACETALKWATCH UK Ltd ( Company Number 11843344) and any of our group companies (together Spacetalk). References to "we," "us," or "our" in this document also refer collectively to Spacetalk.

This Privacy Policy sets out our commitment to protecting the privacy of your personal information provided to us, or otherwise collected, used, stored or disclosed by us when providing our products and services (Services) or when otherwise interacting with you in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth). As a supplier of telecommunication services, we may also have obligations under other laws, regulations and industry codes. We make this Privacy Policy readily available and accessible to all customers, clients and service providers.

By using our website and Services, or in providing any personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

“Personal information” includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.

Spacetalk collects, holds and uses the following categories of Personal Information

When you sign up to or use our Services, we (or third parties on our behalf) may collect the following types of personal information

  • full name and nickname;
  • phone number;
  • email address; 
  • mailing or street address; 
  • age or date of birth; 
  • gender; a photo of you;
  • government identifiers; 
  • password or security pin; 
  • your IP (Internet Protocol) address; 
  • your device ID (such as serial numbers), device type, geo-location (including live location) and network information, computer and connection information, statistics on page views, traffic to and from the sites, ad data and standard web log information; 
  • location data such as live physical location, safe zone parameters, Global Positioning System (GPS), nearby Wi-Fi networks, mobile cell tower triangulation, Near Field Communication (NFC), and RFID; 
  • transaction data including details about payments from you and other details of the products you have purchased from us or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries; 
  • school name, teacher name, school events; 
  • information you provide to us through customer surveys; 
  • payment and other financial information, such as credit card information; and 
  • any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

  • sign up on our website or app;
  • communicate with us through correspondence, chats, email or when you share information with us from other social applications, services or websites; 
  • interact with our sites, services, content and advertising;
  • use our devices, services or products; or 
  • invest in our business or enquire as to a potential purchase in our business.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

You do not have to provide us with any personal information, however, if you do not do so, we may not be able to complete a transaction you have entered into, finalise payment of a Service you have requested, make delivery of a Service you have ordered or signed up to, validate your entry in a promotion, or otherwise provide you with the Services you have requested.

Personal Information and consent of third parties

From time to time, you may provide us, and we may collect from you, personal information of a third party. Where you provide the personal information of a third party, it is your responsibility to ensure that you have obtained their consent to provide their personal information to us and that their details will be collected, stored, used and disclosed in accordance with our Privacy Policy. This includes informing them of the purpose of collection, how their information will be used, and their rights regarding access and correction of their information.

If you are purchasing or signing up to our Services for a minor or a person who you have legal responsibility for, as the parent or legal guardian, you must consider the privacy of the user over whom you have responsibility. You are also responsible for providing necessary consents on behalf of those individuals.

Sensitive Information

Under the Privacy Act, “sensitive information” includes but is not limited to information or an opinion about an individual’s race or ethnic origin, religious belief, or criminal record and also includes health information about an individual.

In certain circumstances, when you use our Services, we may also collect health data including weight, height, average activity levels (including step data), movement/physical ability, medical conditions, heart-rate, medication / prescriptions, fall detection and mood.

How do we collect, hold, use and disclose personal information?

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

  • to enable you to access and use our website and Services;
  • to operate, protect, improve and optimise our website and Services, business and our users’ experience, such as to perform analytics, conduct research, develop new features and for advertising and marketing; 
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you; 
  • to send 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;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; 
  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and 
  • to consider your employment application.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

Live-location services

Where we collect your location data through our Services, we will comply with the relevant Apple App Store and Google Play Store requirements. If you do not want us to use your location data for the purposes above, you should turn off the location services in your account settings in the Spacetalk app or in your mobile phone settings. If you do not provide location data to us, we may not be able to provide our services to you.

Do we use your personal information for direct marketing?

By agreeing to the terms of this Privacy Policy, you agree that we and/or our carefully selected business partners may send you direct marketing communications and information about our Service. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

Who we may disclose your Personal Information to

We work with other companies that help us provide our systems and services to our customers. We may provide personal information to these companies for the purpose of providing the Services to you and to facilitate our interests as stated above. Those service providers will only be provided with access to your personal information as is reasonably necessary for the purpose that we have engaged the service provider, and we will require that such third parties comply with our standards and all applicable laws.

We may disclose personal information to:

  • our employees, contractors and related entities;
  • third party suppliers and service providers (including providers for the operation of our websites and/or our business) or in connection with providing our Services to you;
  • marketing or advertising providers; 
  • IT service providers, data storage, web-hosting and server providers; 
  • professional advisors, dealers, agents, auditors, business brokers, our insurers and insurance brokers; 
  • credit reporting bodies and agencies; 
  • payment systems operators (eg merchants receiving card payments); 
  • our existing or potential agents, business partners or partners; 
  • our sponsors or promoters of any competition that we conduct via our Services
  • your emergency contacts or approved contacts; 
  • anyone to whom our business assets (or any part of them) are, or may (in good faith) be, transferred; 
  • courts, tribunals, governmental agencies, regulatory authorities and law enforcement agencies, or as required, authorised or permitted by law; 
  • third parties to collect and process data including for marketing purposes, such as Google Analytics (To find out how  Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners or any other URL Google may use from time to time);
  • specific third parties authorised by you to receive information held by us; and 
  • any other third parties as required or permitted by law, such as where we receive a summons. 

Credit reporting bodies and agencies

To enable us to provide you with our Services, or when you deal with us in some other way that involves our Services, we may disclose your personal information with credit reporting bodies:

  • the fact that you have applied for credit and the amount;
  • the fact that we are a credit provider to you; and
  • payments which become overdue and for which debt collection action has started. 

We may also use your personal information to:

  • obtain from a credit reporting agency a credit report containing personal data about you in relation to commercial credit provided by us;
  • obtain a report containing information about your commercial activities or commercial creditworthiness from a business which provides information about the commercial creditworthiness of a person; and
  • obtain a report from a credit reporting agency and other information in relation to your commercial credit activities. We may also disclose your personal data to third parties to whom you expressly ask us to send the personal data to or to third parties you consent to us sharing your personal information with.

Every credit reporting body is required by law to have a policy which explains how they manage your personal information. You can view the policy for each of the credit reporting bodies we deal with using the details below:


FrankieOne (Aus): https://frankieone.com/frankieone-privacy-policy
Experian (Aus): https://www.experian.com.au/privacy-policy-terms-conditions
Gigs (USA): https://gigs.com/legal

Overseas Transfers of personal information

As we operate on a global scale, we may store and process personal information in a cloud services or data centres located outside the country in which you are located, including but not limited to Australia, the United States and the United Kingdomor in any country where we or our service providers operate.

For the provision of customer support, to troubleshoot issues or for other IT or marketing services, we may give controlled access of our systems to suppliers or personnel located outside of the country where you are located. Any such access is provided strictly under applicable data protection laws, contractual safeguards, and security measures designed to protect your personal information.

Additionally, we may disclose personal information overseas when required by legal or regulatory obligations, such as responding to a lawful request from a foreign law enforcement body.

We take reasonable steps to ensure that any international transfer of personal information is carefully managed to protect your privacy rights and interests. This includes implementing measures such as encryption, pseudonymisation, and contractual safeguards to ensure your data is handled securely and in compliance with applicable privacy laws.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use cookies, pixels and other third-party tracking technologies on our websites from time to time. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Some “functional” cookies are used in providing our web-based application services to you. These are required to provide access to our systems and enable the user experience. These cookies are not shared with or used by third parties.

Use of personal information by Google Analytics

We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Data Storage

We are committed to ensuring that the personal information we collect is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we align with SOC2 Type II security control framework. However, we cannot guarantee the security of your personal information.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Unsubscribe

To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details set out below or opt-out using the opt-out facilities provided in the communication.

Accessing or correcting your personal information

You may have the right to ask for your personal information by requesting:

  • a copy of your personal information;
  • that we correct inaccuracies relating to your personal information;
  • that your Personal information be deleted or that we restrict access to it; and
  • a structured electronic version of your personal information.

You may also have the right to object to our use of your personal information.

Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information, we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Should you wish to make a request in respect of your personal information please contact us at privacy@spacetalk.co.

Enquiries, Requests, Complaints, Breaches

You can make enquiries or complaints regarding this Privacy Policy or the Personal information we hold on you to our customer service team, whose contact details are below. We will take all reasonable steps to ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances. If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the relevant regulatory authority, whose contact details are below:

Individuals based in Australia

Office of the Australian Information Commissioner

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au 

Address: Level 3, 175 Pitt Street, Sydney NSW 2000, Australia

Individuals based in New Zealand

Office of the Privacy Commissioner

Telephone: 0800 803 909

Email: enquiries@privacy.org.nz

Address: PO Box 10 094, Wellington 6140

Individuals based in the United Kingdom

Information Commissioner's Office

Telephone: +44 (0) 303 123 1113

Email: casework@ico.org.uk

Address: Wycliffe House, Water Lane, Wilmslow SK9 5AF, United Kingdom

Individuals based in the United States

Refer to your relevant State privacy and data protection body

Individuals based in Canada

Office of the Privacy Commissioner of Canada

Phone: +1 819-994-5444

Address: 30 Rue Victoria, Gatineau, QC J8X 2A1, Canada

Individuals based in the Netherlands

The Dutch Data Protection Authority (DPA)

Telephone: +31 (0)88 1805 250

Email: fg@minaz.nl

Address: Dutch Personal Data Authority, PO Box 93374, 2509 AJ The Hague

Individuals based in France

National Commission on Informatics and Liberty

Telephone: +33 (0)1 53 73 22 22

Address: 3 Place de Fontenoy, 75334 Paris Cedex 07

Individuals based in Germany

German Federal Commissioner for Data Protection and Freedom of Information (BfDI)

Telephone: +49 (0)228-997799-0

Email: poststelle@bfdi.bund.de

Address: Graurheindorfer Straße 153, 53117 Bonn

Individuals based in Spain

Spanish Data Protection Agency

Telephone: +34 901 100 099 / +34 91 266 35 17

Website: www.aepd.es.

Address: C/Jorge Juan, 6, 28001 Madrid

Individuals based in Singapore

The Personal Data Protection Commission (PDPC)

Telephone: +65 6377 3131

Address: 10 Pasir Panjang Road #03-01, Mapletree Business City, Singapore 117438

Individuals based in Ireland

Irish Data Protection Commission (DPC)

Telephone: (01) 765 01 00 or 1800 437 437

Email: info@dataprotection.ie

Postal Address: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

 

For any questions or notices, please contact us at:

Spacetalk

Telephone: +61 (0) 8 8104 9588

Email: privacy@spacetalk.co

Address: 154 Fullarton Road, Rose Park, South Australia 5067 Australia

Website: www.spacetalk.co

 

For Individuals based in the United Kingdom

Telephone: +44 (0) 208 0175868

Email: privacy@spacetalkwatch.co.uk

Address: Office 9, Business First Burnbrae Road, Linwood Industrial Estate, Paisely PA3 3FP, United Kingdom

Website: http://www.spacetalkwatch.co.uk/