Personal information: The types of personal information or personal data we may collect about you include:
• your name;
• your contact details, including email address, mailing address, street address and/or telephone number;
• your marital status and/or anniversary;
• your age and/or date of birth;
• your demographic information, such as postcode;
• credit card details; and
• any other personal information requested by us and/or provided by you or a third party.
We may collect these types of personal information directly from you or from third parties.
Collection and Use of Personal Information
We may collect, hold, use and disclose personal information for the following purposes:
• to enable you to access and use our services or the services of our customers;
• to contact and communicate with you;
• for internal record keeping and administrative purposes; and
• to comply with our legal obligations and resolve any disputes that we may have.
Disclosure of Personal Information to third parties
We may disclose personal information to:
• third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred; and
• courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.
Please note that we use the following third parties to process your personal information:
• Microsoft Azure.
By providing us with personal information, you consent to the disclosure of your personal information to third parties who are outside Australia and, if you are a European Union (EU) citizen, to third parties that are outside the EU. Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the GDPR), you acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
Our Responsibilities as a ‘processor’ under the GDPR
Where we are a processor, we have contracts containing certain prescribed terms in our contracts with controllers. In addition to our contractual obligations with controllers, where we are solely a processor we also have the following responsibilities under the GDPR:
– not to use a sub-processor without the prior written authorisation of the data controller;
– to co-operate with supervisory authorities;
– to ensure the security of its processing;
– to keep records of processing activities;
– to notify any personal data breaches to the data controller; and
– to employ a data protection officer and appoint (in writing) a representative within the European Union if required by the GDPR. (These are not required for the company at the present time).
Your Rights and Controlling your Personal Information
Complaints: If you believe that we have breached the Australian Privacy Principles or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the Office of the Australian Information Commissioner if you wish to make a complaint.
Storage and Security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Cookies and Web Beacons
We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behavior and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
Links to other Websites
For any questions or notices, please contact our Privacy Officer at:
Smart Messaging Services Pty Ltd ABN 56 122 125 240 trading as Intellimessaging
Level 5, 171 Collins Street, Melbourne VIC 3000
Last update: 9 March, 2018