EFFECTIVE DATE: 14 NOVEMBER 2014
INTRODUCTION
Snowden wants you to be familiar with how we collect, use and disclose information from and about you in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (the Act). This Privacy Policy describes our practices regarding this information which is collected through all our services including, but not limited to, our websites, downloadable commercial software, online hosted solutions, consultancy services, training and education courses and surveys (collectively, the “Services”). By using the Services or otherwise providing us directly, or through others, with your personal information, you consent to the collection, transfer, processing, storage, disclosure and other uses of this information as described in this Privacy Policy.
INFORMATION WE COLLECT
Snowden collects the personal information directly from you, and only to the extent needed to provide the Services or for our own internal administrative and business operations. If you choose not to provide certain personal information to us, we may not be able to provide you with the Services you require. The following sets out the types of personal information collected by Snowden.
Account and Profile Information: We collect information about you and your company when you register for an account, create or modify your profile, make purchases through, use, access, or interact with the Services. Information we collect about you includes but is not limited to your name, username, address, email address, phone number or credit card details. You may provide this information directly when you apply for the Services or in some cases a Snowden employee creating an account on your or your company’s behalf may provide it to us. If you are providing information (including personal information) about someone else, you must confirm that you have the authority to act for them and to consent to the collection and use of their personal information as described in this Privacy Policy.
Content: We collect and store content that you create, input, submit, post, upload, transmit, store or display in the process of using our Services. Such content includes any personal information or other sensitive information that you choose to include. The meaning of “personal information” and “sensitive information” in this Privacy Policy is as described in the Act.
Career and Work Experience Information:We collect and store personal career and work experience information when you apply directly or indirectly for advertised positions or submit a general expressions of interest for work. Information we collect includes resumes, cover letters, contact details such as name, address, email address and phone number, and in some cases answers to specific questions regarding your work history.
General Activity– cookies and other technologies: We use various technologies to collect information, including cookies that are saved to your computer or mobile device. When you access and interact with the Services, we may collect certain information about those visits in these cookies. For example when you access our website, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information from that device.
Cookies and other tracking technologies are comprised of small bits of data or code that often include a de-identified or anonymous unique identifier. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Services. Please consult the “Help” section of your browser for more information.
Analytics Collection: We may collect analytics information when you use our Downloadable Commercial Software or Hosted Services (“Products”) to help us improve our Products and Services. These Products contain a feature that sends information about the technical operation of the Products (“System Information”) to us. System Information includes information about (a) client information, for example: browser type and version, native client type and version, and client device specifications (e.g. screen resolution, OS version, device type, etc.) and (b) the features that are being accessed and used in the Product.
HOW WE STORE AND SECURE INFORMATION
We will take reasonable steps to keep any personal information we hold about you secure. The information we collect is stored in our internal operational systems such as our customer relationship, licensing, project management and HR systems. In some cases, a copy of the personal information is made to prevent accidental loss of the data through server malfunction or human error. The locations of these systems may be in Australia or located overseas in cloud based data centres.
We implement a range of physical and electronic security measures to protect the personal information that we hold, including:
- Secure offsite hard copy storage of documents
- Access to systems and applications is restricted to authorised personnel only
- All visitors are authorised before entering areas where personal information is processed or accessed
- Access to Snowden offices is only via secure key cards
- We encrypt many of our services using SSL
- All authorised personnel are assigned unique personal identification codes and secure means of authentication into systems that store personal information
PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION
We use the information we collect from and about you to provide the Services, Products and features to you, including to:
- measure and improve those Services, Products and features;
- provide you with customer support and to respond to inquiries;
- provide you consulting and educational services;
- process and complete transactions, and send you related information, including purchases and invoices;
- communicate with you, including responding to your comments, questions, and requests; providing customer service and support; providing you with information about services, features, surveys, newsletters, offers, promotions, contests and events; and sending you technical notices, updates, security alerts, and support and administrative messages; and
- investigate and prevent fraudulent transactions, unauthorized access to Services, and other potentially illegal activities.
HOW WE USE INFORMATION WE COLLECT
We may use and disclose your personal information for the purpose for which it was collected.
We will also use and disclose your personal information for a secondary purpose that is related to a purpose for which we collected it, where you would reasonably expect us to use or disclose your personal information for that secondary purpose.
Other instances when we may use and disclose your personal information include:
- where you have expressly or impliedly consented to the use or disclosure; or
- where the use or disclosure is authorised or required by or under an Australian law or court or by tribunal order
HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose your personal information to third parties including:
- SFDC Australia Pty Ltd (SalesForce), Sydney, NSW, Australia
- Recurly Inc, San Francisco, CA, USA
- Amazon Web Services Inc, WA, USA
- PayPal Australia Pty Ltd, NSW, Australia
CHANGES TO THIS POLICY
We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Effective Date” at the top of this Privacy Policy. We encourage you to review our Privacy Policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.
ACCESSING AND UPDATING YOUR INFORMATION
You have a right to request access to or correction of your personal information held by us. If you wish to access, correct or update any personal information we may hold about you, please contact us as set out below. However, we may charge for providing access to this information and we may refuse access where the Act allows us to do so. You can access and modify some of the information we keep about you through your Snowden account settings.
COMPLAINTS
If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy or the Act, please contact us as set out below. Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint to the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
Office of the Australian Information Commissioner (OAIC) Complaints must be made in writing
| 1300 363 992 | |
| Director of Compliance Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 | |
| www.oaic.gov.au |
INTERNATIONAL USERS [AND DISCLOSURE]
If you access or use the Services from regions with laws governing data collection and use (such as the European Union), you are agreeing to the transfer of your personal information to Australia. Snowden may also use services from third parties that process and store your personal information in data centres located outside of Australia, including the United States of America, Singapore and Brazil. By providing your personal information, you consent to any transfer and processing of this data in accordance with this Policy.
CONTACT US
If you have any queries in relation to how your personal information is handled by us, please contact our Privacy Officer at:
Snowden Privacy Officer
Level 6, 130 Stirling Street, Perth, WA, 6000
+61 (08) 9213 9213
Email: moc.p1606159563uorgn1606159563edwon1606159563s@tro1606159563ppuse1606159563rawtf1606159563os1606159563