CA Management Services Pty Ltd Limited (CAMAN)

Engaje Privacy & Data Collection Policy

Introduction

CA Management Services Pty Ltd Limited complies with all privacy laws in the countries and territories in which we operate when dealing with personal information. Personal information is information about an identifiable individual. This Policy sets out how CAMAN will collect, use, disclose and protect your personal information. This Policy does not limit or exclude any of your rights under any Privacy Act Law.

What personal information do we collect

We collect, hold and process two categories of personal information:

1. Account and Marketing Data is personal information that we collect about you:

2. In connection with the creation or administration of a customer account

3. if you ask to receive information about us or our services and products or sign up for our newsletter when you contact us directly (e.g. telephone call, email or through the user dashboard) or visit our website.

The Account and Marketing Data we collect may include company/personal names, usernames, phone numbers, email addresses, your location, billing information, information about how you use our website or the Services (for example, traffic volumes, time spent on pages), your IP address and/or other device identifying data, and other information required to provide a service or information you have requested from us.

Visitor or Employee Data is personal information about a customer’s visitors or employees that is input into the Engaje or CAMAN service. Visitor and Employee Data may include visitors’ and employees’ names, phone numbers, email addresses, locations and photos, times of visit, visitors’ employers’ names, and any other information that a customer decides to capture about its visitors and employees.

CAMAN will not disclose, move, access, process or use Visitor or Employee Data except as provided in our terms of service. We require customers to comply with applicable privacy and data protection laws.

The remainder of this Policy sets out how we will collect, use, disclose and protect Account and Marketing Data and does not apply to Visitor or Employee Data.

Who do we collect your personal information from

We collect personal information about you from:

1. you, when you provide that personal information to us, including via our website, mobile app and the Service, through any registration process and through any contact with us (e.g. telephone call, email or through the user dashboard, mobile app)

2. third parties where you have authorised this or the information is publicly available.

3. If possible, we will collect personal information from you directly.

When you visit or use our website or the Service, we may collect information about you:

1. by recording clickstream data, which is non-personal information that is recorded when you use our signup service a webpage,mobile app and is used for the purposes of collecting, analysing and reporting data about how you use our website, mobile app and our services; and

2. through the use of cookies, pixel tags (also known as web beacons or clear gifs) and similar storage technologies.

Some provision of personal information is optional. However, if you do not provide us with certain types of personal information, you may be unable to enjoy the full functionality of our website or services.

We may also conduct user surveys to collect information about your preferences. These surveys are optional and if you choose to respond, your responses will be kept anonymous. Similarly, we may offer contests to qualifying users in which we ask for contact and demographic information such as name, email address and mailing address. None of this information is shared with third parties, except in summary form, if at all. Information we gather through a contest may also be disclosed to third parties as necessary for prize fulfilment and other aspects of any contest or similar offering.

How we use your personal information

We will use your personal information:

• to verify your identity

• to provide services and products to you

• to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)

• to improve the services and products that we provide to you

• to bill you and to collect money that you owe us, including authorising and processing credit card transactions

• to respond to communications from you, including a complaint

• to conduct research and statistical analysis (on an anonymised basis)

• to protect and enforce our legal rights and interests, including defending any claim

• for any other purpose authorised by you or Privacy Law

Disclosing your personal information

We may disclose your personal information to:

• any other company within the CAMAN group for the purposes described in this Policy

• any business that supports our services and products, including any person who hosts or maintains any underlying IT system or data centre that we use to provide the Website or other services and products or who assists us with our marketing and customer care activities described in this Policy

• other third parties (for anonymised statistical information)

• a person who can require us to supply your personal information (e.g. a regulatory authority)

• any other person authorised by Privacy Law (e.g. a law enforcement agency)

• any other person authorised by you

• any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

A business that supports our services and products may be located outside the country in which you have entered your personal information. This may mean your personal information is held and processed outside the country you have provided it.

We also share information about your use of the Website with our trusted social media, advertising and analytics partners through the use of cookies, pixel tags and similar storage technologies.

Protecting your personal information

We will take all steps deemed reasonable to keep your personal information safe from loss, unauthorised activity, or other misuse.

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in Privacy Law, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at [email protected] Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

Internet Use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website or in the Service to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.

Changes to this policy

CAMAN may change this Policy by uploading a revised Policy onto its website (www.engaje.com.au the Website). Unless stated otherwise, the change will apply from the date that the revised Policy is up by CAMAN.

If you follow a link on our website or in the Service to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.

Contact us

If you have any questions about this Policy or our privacy practices, you can contact us at [email protected]

Privacy & Data Collection Policy Last Updated 14th June 2020.