Welcome to our website. In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Toro Digital Pty Ltd (ABN 76 164 797 997) t/as Toro Digital. We are committed to respecting your privacy and understand that protecting your personal information is important. Our Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website and digital marketing services (Services) or when otherwise interacting with you.
Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not it may affect our ability to provide our Services to you and your use of our Services.
By providing 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.
What is personal information?
Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual that is identified or reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details.
What personal information do we collect?
We may collect the following types of personal information about you:
When you are a user of our digital marketing services:
- your username and password;
- your name;
- your contact details including your work email address and/or telephone number;
- your job title and employer and/or workplace details;
- support requests submitted to us and our response to you; and
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour.
When you visit our website:
- name;
- mailing or street address;
- email address;
- telephone number and other contact details;
- your job title and employer and/or workplace details;
- information you provide to us through, including through feedback, customer surveys or otherwise;
- age or date of birth;
- credit card information;
- support requests submitted to us and our response to you;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys; or
- any other personal information that may be required in order to facilitate your dealings with us.
Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.
How do we collect personal information?
We may collect these listed types of personal information either directly from you, or from third parties.
We may collect this personal information in a number of ways, including:
- Directly: we collect personal information which you directly provide to us, including when you subscribe to our digital marketing insights, use our website for access to the Upload Portal and the Analytics Portal, complete any forms on our website, communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
- Indirectly: we may collect personal information which you indirectly provide to us while you interact with our sites, services, content and advertising; or
- From third parties: we collect personal information from third parties, such as when you invest in our business or enquire as to a potential purchase in our business, 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 1988 (Cth).
Why do we collect, 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 Services including to provide you with a login;
- to provide our Services to you;
- to operate, protect, improve and optimise our website, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to enable you to access and use our associated applications and platforms including the feedback platform;
- 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;
- for internal record keeping, administrative, invoicing and billing purposes;
- 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;
- if otherwise required or authorised by law; 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.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about our service and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act 1988 (Cth). 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).
To whom do we disclose your personal information?
We may disclose personal information for the purposes described in this Privacy Policy to the following third parties:
- our employees and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
- professional advisers, dealers and agents;
- 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;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us;
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, 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), Facebook Pixel or other relevant analytics businesses; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to third party suppliers such as cloud providers, web applications and software-as-a-service located around the world whom may store, transfer or access personal information outside of Australia.
We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Using our website and cookies
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 use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
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 1988 (Cth). 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.
Storage and Security
We are committed to ensuring that the personal information we collect is secure.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from unauthorised access or disclosure, misuse, interference, loss and unauthorised access, and we use a number of physical, administrative, electronic, managerial and technical measures to protect your personal information. For example, we employ two-factor authorisation where possible on all our software systems, use a password manager with long and randomly generated passwords to ensure access is as secure as possible.
We also perform regular updates on our website to prevent against malicious attacks. However, we cannot guarantee the security of any information that is transmitted to or by us over the internet. The transmission and exchange of information is carried out at your own risk.
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.
Accessing or correcting your personal information
Access: You can access the personal information we hold about you by contacting us using the ‘contact us’ function. 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 we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you think that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us and we will take reasonable steps to ensure that it is corrected. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Making a complaint
If you think we have breached the Privacy Act 1988 (Cth), or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below.
Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Paul Evans
Managing Director
Level 23, Tower Five, Collins Square
727 Collins Street
Melbourne, VIC 3008
paul.evans@torodigital.com.au
+61 3 8362 3729
Effective: 24 November 2021