Suggesterfy Privacy Policy  

‍

1. Introduction

‍

1. Our website suggesterfy.com (Site) and the Suggesterfy mobile application (the Suggesterfy App) are created, operated and controlled by Suggesterfy Pty Ltd (ACN 656 108 422) (Suggesterfy, we, us or our).

‍

2. We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
3. By visiting or using our Site or downloading, accessing and using the Suggesterfy App (including viewing, sharing, posting or publishing suggestions and recommendations on, or via the Suggesterfy App), you agree to this Privacy Policy. 

‍

4. This Privacy Policy outlines how we collect, store, process, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

‍

2. The information Suggesterfy collect about you

‍

1. Personal Information

‍

1. Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.

‍

2. Suggesterfy collect and use Personal Information and Non-Personal Information from visitors to our Site, from users of the Suggesterfy App and from advertising partners who advertise on, or via, the Suggesterfy App, and any other individual who interacts with us.

‍

3. Suggesterfy will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver our Site, make the Suggesterfy App and our products and services available to you, or as otherwise permitted by law. 

‍

4. The type of Personal Information and Non-Personal Information that we collect and use depends on the type of dealings that you have with us.

‍

2. Users

We collect and hold Personal Information about users of the Suggesterfy App as well as information or data that does not contain Personal Information. For example, the type of Personal Information and non-Personal Information that we collect includes:

1. registration details and user profile information (for example, full name, email address, date of birth, mobile number, and profile picture or image);

‍

2. account credentials (for example, any username and password created by you as a user of the Suggesterfy App); 

‍

3. any content, information and other data that you post when making suggestions or recommendations (or requesting recommendations or suggestions) on, or via the Suggesterfy App (such as information about your interests, hobbies, activities); 

‍

4. location information (such as locations or places suggested or recommended by you or other users) and other information to analyse and track usage of the Suggesterfy App;

‍

5. information relating to your dealings, or enquiries you have made, with us, including information about the Suggesterfy App (or other products and services) you have ordered or purchased from us;

‍

6. device information which is automatically collected from you when you visit and navigate through the Suggesterfy App.  Such information may include, but is not limited to, your device type; your device’s network connections; unique device identifier, your device’s name; your device IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the Suggesterfy App, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the Suggesterfy App and other usage statistics; and

‍

7. other information that you provide to us or that we may collect in the course of our relationship with you.

‍

3. Advertising partners

We collect and hold Personal Information as well as information or data that does not contain Personal Information about advertisers that promote their products and/or services to users on, or via, the Suggesterfy App. For example, the type of Personal Information and non-Personal Information that we collect includes:

‍

1. advertising partner details (for example, business name, ABN, ACN or other business/company identifiers, email address and address);

‍

2. contact details of the advertising partner’s authorised representatives (such as, full name, job title, business phone number, business email address and office address); 

‍

3. information about the advertising partner’s products and/or services promoted or advertised on, or via, the Suggesterfy App (such as the advertising partner’s business logo, address, phone number, email address, website address, products and services and promotions); 

‍

4. payment or billing details (for example, credit card and debit card);

‍

5. information relating to your dealings, or enquiries you have made, with us in relation to the Suggesterfy App, our products and services; and 

‍

6. other information that you provide to us or that we may collect in the course of our relationship with you.

‍

4. Other information

‍

1. Suggesterfy may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, Suggesterfy may collect anonymous answers to surveys or aggregated information about how users or advertising partner’s use our Site or the Suggesterfy App.

‍

2. If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.

‍

5. Sensitive Information

‍

1. We do not collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information. 

‍

2. If you have accidentally sent us Sensitive Information, please contact us using the details below.

‍

3.  How Suggesterfy collect Personal Information

‍

1. Direct collection from you 

‍

1. We will collect Personal Information and Non-Personal Information about you in a number of different ways. We may collect Personal Information and Non-Personal Information directly from you or in the course of our dealings with you. For example:

‍

1. in the case of users, when you:

1. download, access and use the Suggesterfy App (including when you open an account or create or update your account or user profile on, or, via, the Suggesterfy App); and
2. post, publish or submit suggestions or recommendations (or post or publish a request for suggestions or recommendations) on the newsfeed within the Suggesterfy App;

2. in the case of advertising partners, when you:

1. download, access and use the Suggesterfy App (including when you open an enterprise account or create or update your enterprise account on, or, via, the Suggesterfy App);
2. create, publish, submit or share marketing campaigns and advertisements or otherwise promote your business on, or, via, the Suggesterfy App; and
3. contact or correspond with us via email or telephone or when you submit our query through our Site in relation to advertising or promoting your products and services to users on, or via, the Suggesterfy App.

‍

3. when you visit the Site or submit information through the Suggesterfy App or our Site (including on, or via, our related social media accounts), contact us, or complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and
4. when you otherwise contact, interact or communicate with us (such as by telephone, email or in person) with a query or request or make a comment on our social media sites or lodge a complaint about another user or advertising partner on, or via, the Suggesterfy App; and

1. when otherwise legally authorised or required to do so.

‍

2. When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection. 

‍

3. By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

‍

2. Collection from third parties

1. We may also collect Personal Information and Non-Personal Information about you from publicly available sources and third parties, including:

1. when you provide your Personal Information to our Authorised Affiliates or other third parties;
2. from other users of the Suggesterfy App when you post or publish a recommendation or suggestion to the newsfeed, or when you post or publish a request for recommendations or suggestions to the newsfeed; 
3. if you use: 

1. our social media sites or applications, pages or plugins; or 
2. third party products or services that interact with the Suggesterfy App, our products, services or Site.

1. if third party payment processors are used by us to process payments made by you. Suggesterfy do not collect, process, use, share, store or disclose any payment information (such as credit card and bank account details). Rather, all such information is provided directly to Suggesterfy’s third party payment processors whose use of your Personal Information (including payment information) is governed by their privacy policy.

1. When Suggesterfy collects your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
2. If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to: 

1. inform them that you are providing their Personal Information to us; and  
2. advise them that they can contact us for further information. 

1. You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us. 
2. Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

‍

4. How Suggesterfy use your Personal Information 

‍

1. Purposes of use and disclosure

1. Suggesterfy only use, process and disclose your Personal Information for the purposes for which it is collected.
2. In particular, Suggesterfy use, process and disclose your Personal Information and Non-Personal Information to: 

1. provide or deliver the Suggesterfy App, our products, services or Site to you, including, without limitation, to:

1. provide users with the opportunity to: (1) post or publish a recommendation or suggestion to your private connections; or (2) request recommendations or suggestions from your private connections; or (3) access and view (via the newsfeed within the Suggesterfy App) statistical information and non-Personal Information about suggestions or recommendations made by all users of the Suggesterfy App relating to a venue, place, activity, product or service; 
2. provide advertising partners with an opportunity to: (1) advertise or promote their venue, activities, products or services to users on, or via, the Suggesterfy App; and (2) direct or link their website to the Suggesterfy App; and

1. confirm a user’s and advertising partner’s identity; 
2. assisting with, or responding to, your queries or responding to, or investigating, complaints raised by you about other users of the Suggesterfy App or advertising partners;
3. informing you about the Suggesterfy App, our Site, products or services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the Suggesterfy App, the Site, advertising partners, or other matters which we believe are of interest to you (such as recruitment or job opportunities);
4. manage, administer, improve, test, develop and upgrade the Suggesterfy App, our Site and our products and services (including customising the advertising and content on the Suggesterfy App and Site), informing you about scheduled maintenance or outages and managing our relationship with you;
5. share with our Authorised Affiliates;
6. charge and bill you to advertise on the Suggesterfy App or to otherwise access and use the Suggesterfy App, our products and services;
7. for internal record keeping;
8. for direct marketing purposes (see below); 
9. complying with our legal and regulatory obligations;
10. for any purpose to which you have consented; and
11. for any other purpose notified to you at the time of collection.

3. When you publish or post recommendations or suggestions (or post or a publish a request for recommendations or suggestions) to the newsfeed only your private connections can see your user profile. Your user profile contains:

1. your username and your user profile image; 
2. all of the questions, recommendations or suggestions you have posted, submitted or published to your private connections; and
3. your list of private connections.  

4. In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you. 

2. Disclosure to Authorised Affiliates

1. In order to provide or deliver the Suggesterfy App, our Site, products or services to you, we may disclose your Personal Information and Non-Personal Information to:

1. our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers; 
2. authorised external service providers who perform functions on our behalf, such as financial and credit card institutions, third party payment processors in order to process any payments, internet and technology services providers, app and website software developers, hosting companies, marketing, advertising and security service providers, fulfilment companies, credit reporting agents, debt collection agents, market research and recruitment service providers; and
3. external business advisors, such as auditors, lawyers, insurers and financiers,

(collectively, Authorised Affiliates).

2. We may share your de-identified demographic information (such as your age) with our advertising partners who may use the demographic information for advertising purposes on, or via, the Suggesterfy App. 
3. We may also disclose your Personal Information and Non-Personal Information:

1. to any other party with your consent and direction; 
2. to law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law; or
3. where we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard. 

2. When we disclose your Personal Information or Non-Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. These Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.
3. Our Authorised Affiliates may also provide us with Personal Information and Non-Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliates, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.

3. Overseas disclosure

1. In the course of providing you with access to, and use of, the Suggesterfy App and Site, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located in Australia and overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. Our data storage and hosting provider is located in Australia. However, in the course of processing payments made to us we commonly disclose Personal Information (including payment information) to our third party payment processors located in the United States and elsewhere in the world.
2. The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, Suggesterfy will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
3. By accessing or using the Suggesterfy App and our Site, or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to our overseas Authorised Affiliates. If you do not wish to receive information from any of our Authorised Affiliates, please let us know using the details below. However, if you do not provide your Personal Information to us or our Authorised Affiliates, we may not be able to provide you with access to, and use of, the Suggesterfy App or Site.

4. Disclaimer

1. Suggesterfy will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless: 

1. we are otherwise required by the relevant Privacy Laws; 
2. we are permitted to under this Privacy Policy; or 
3. such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the Suggesterfy App or Site.

2. This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.

‍

5. Notifiable Data Breaches Scheme

‍

In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, Suggesterfy will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.

‍

6. Marketing communications

‍

1. Direct marketing

1. Suggesterfy may use and disclose your Personal Information to send you information about the Suggesterfy App, our Site, recommendations or suggestions about venues, activities, products or suggestions published or posted by your private connections or information about other products or services we may offer from time to time, as well as other information that may be of interest to you. 
2. These communications may continue, even after you stop using the Suggesterfy App.

2. Communication channels

1. Suggesterfy may send this information to you via the communication channels specified at the time you provide your consent. 
2. These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices or advertising on the Suggesterfy App.

3. Opting-out

You can opt out of receiving these communications by:  

1. contacting us using the details below; or
2. using the unsubscribe function in the email or SMS.

‍

7. Storage and security 

‍

1. Protecting your Personal Information

‍

1. We take reasonable steps in the circumstances to keep your Personal Information and Non-Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information and Non-Personal Information.
2. Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.
3. Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information and Non-Personal Information take reasonable steps to:

1. protect and maintain the security of your Personal Information and Non-Personal Information; and 
2. comply with the Australian Privacy Principles when accessing and using your Personal Information. 

2. No guarantee

1. The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information and Non-Personal Information, we cannot guarantee the security of any Personal Information and Non-Personal Information transmitted through the Suggesterfy App or Site. 
2. You provide your Personal Information and Non-Personal Information to us at your own risk and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information and Non-Personal Information.

‍

3. Destruction of Personal Information

‍

1. We will destroy or de-identify Personal Information in circumstances where it is no longer required, unless we are required or authorised by law to retain the information.
2. Any suggestions or recommendations posted, published or submitted by a user on the newsfeed on the Suggesterfy App will not be deleted. However, your profile information (including Personal Information) will be de-identified and so will not be visible to other users of the Suggesterfy App. 

‍

8. Accessing and correcting your Personal Information

1. Suggesterfy shall use our reasonable endeavours to keep your Personal Information accurate, up-to-date and complete. You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act. 
2. You can access, or request that we correct, your Personal Information by writing to us using the details below. Suggesterfy may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing. 
3. We will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.
4. We will endeavour to respond to your request for access or correction within 1 month from your request.

8. Cookies policy

1. Suggesterfy and its Authorised Affiliates may collect information by automated means when you access and use the Suggesterfy App or our Site by utilising features and technologies of your internet browser, including cookies and similar technologies. A cookie is a piece of data that enables us to track and target your preferences. 
2. The type of information we and our Authorised Affiliates collect may include statistical information, details of your device and operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links which you have clicked and the type of browser that you were using and browser and login authentication status.
3. We may use cookies and similar technologies to: 

1. enable us to identify you as a return user, make it easier for you to login to the Suggesterfy App and personalise and enhance your experience and use of the Suggesterfy App or our Site; 
2. help us improve our products and service when you access and use the Suggesterfy App or our Site and to ensure that the Suggesterfy App and our Site remain easy to use and navigate; and
3. analyse trends, administer the Suggesterfy App, our Site and other websites we operate, track traffic patterns and gather demographic information.

4. Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or warn you before accepting cookies. 
5. If you reject our cookies or similar technologies, you may still use the Suggesterfy App or our Site but may only have limited functionality of the Suggesterfy App or our Site. 

10. Children's policy

1. We do not knowingly seek, collect or process Personal Information from or about persons under the age of 16 years of age (Children) without the consent of a parent or guardian.
2. If we become aware that any Personal Information relating to a Child has been provided without the consent of a parent or guardian, we will use reasonable endeavours to:

(i) delete the Personal Information from all relevant files as soon as possible; or

(ii) ensure, where deletion is not possible, that the Personal Information is not used further for any purpose or disclosed further to any Authorised Affiliate.

3. Any parent or guardian with queries regarding our collection, use, processing or disclosure of Personal Information relating to their Child should contact us using the details below.

‍

11. Privacy complaints

‍

1. If you have any issues about this Privacy Policy or the way Suggesterfy handle your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
2. At all times, privacy complaints:

1. will be treated seriously;
2. will be dealt with promptly;
3. will be dealt with in a confidential manner; and
4. will not affect your existing obligations or your commercial arrangements with us.

3. Our Privacy Officer will endeavour to:

1. respond to you within 10 business days; and

5. investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.

4. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner. 

‍

12. How to contact us

‍

Suggesterfy can be contacted by email at info@suggesterfy.com.

‍

13. Changes to this Privacy Policy

‍

1. From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our Site or on the Suggesterfy App. 
2. We encourage you to check our Site or the Suggesterfy App from time to time to ensure you are familiar with our latest Privacy Policy.

‍

‍