1. What kinds of information do we collect?
Information about you
Spiire collects information provided by you including through the Contact Us page on its Website, when registering for the App, and through your use of the App. We will endeavour to collect this information directly from you, unless it is otherwise impractical or unreasonable to do so.
The main ways we collect personal information about you are when:
- you access the Website;
- you complete and submit the Contact Us form on the Website;
- you download the App;
- you register for a Spiire account;
- you log onto or visit the App;
- the App is running on your phone, apple watch or other device (device);
- you provide personal information through the App or the Website;
- you attend any Spiire event at which a photographer may be present and capturing images of your attendance at such an event; or
- you otherwise submit personal information about yourself, or someone else, to the App or the Website.
We collect a range of personal information relevant to our advised purposes. The type of information that we collect from you when registering for the App or accessing the Website may include identification information, including first and last names, address, job title, contact information, email address, demographic information, postcode, preferences, interests, career information, phone number, profile photo, date of birth, gender, occupation, living situation and any other personal information that you submit to the Website or the App.
The type of information that we collect from you via the App or the Website may include information relating to third parties, in which case you warrant that you have obtained the consent of third parties to provide that information to us. In the case of information about minors, you warrant that you have the consent of their parent or guardian to provide that information.
If you do not provide the requested information, we may not be able to provide you with access to, or full use of, the App or the Website.
If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.
We collect information from or about the device where you install or access the App, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent services across your devices. Here are some examples of the device information we collect:
- attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.
- device locations, including specific geographic locations, such as through GPS, Bluetooth, or Wi-Fi signals. For example, there may be some activities on the App where you will be required to enable location based services on your device.
- connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
2. Use of Personal Information
Your personal information may be used by us in a number of ways, including the following:
- to provide the products and services offered on the Website and the App and in any other forum to our clients;
- to understand your needs and provide you with a better service;
- to contact you by email, phone, or mail, and enable you to contact us for feedback, comments, queries and complaints submitted via the App or the Website or by any other means;
- to provide market research, strategic branding and marketing services to our clients but we will not disclose your personal information to these parties unless we have your consent to disclose your personal information and we take reasonable steps to ensure your personal information cannot be linked to the insights you provide us through your participation in the App or access to the Website;
- to customise the Website or the App according to your interests and based on the information you provide to us;
- to verify your identity for the purposes of determining your eligibility to participate in the activities offered via the App or on the Website;
- to assess your eligibility to participate in the activities offered via the App and tailor the activities and communications best suited to you;
- to further advertise the services offered via the App and the Website;
- to enhance and improve your use of the App and our products and services;
- for internal business purposes, for example, for the purposes of internal record keeping and to research and develop the App, the Website, and our other products and services;
- in the case of photographs taken at events attended by you, for use by us in any Spiire printed publications and promotional material, and on websites and social media relating to the Spiire business; and
- as required or authorised by law, including under the Australian Privacy Principles.
3. Use and disclosure of information
We will only use personal information for the purposes for which it was given to us, or for purposes which are directly related to the provision of our services.
In certain circumstances, it may be necessary for us to disclose your personal information to third parties in order to assist us in providing our services, or where disclosure is required by us to meet our legal and regulatory obligations. Third parties may include:
- our clients, but only if we have your consent to disclose your personal information and we take reasonable steps to ensure your personal information cannot be linked to the insights you provide us through your participation in the App or Website;
- hosting services for the website and database, such as Amazon, Inc.;
- communication services such as Message Media, to enable us to communicate with you;
- technology support services;
- contractors, designers, and developers for the App or the Website;
- government and law enforcement agencies and regulators; and
- entities established to help identify illegal activities and prevent fraud.
We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies (as defined in Section 16A of the Privacy Act).
4. Disclosure to overseas recipients or third parties
We may also collect personal information from third parties such as your representatives or external data suppliers. When we have collected personal information about you, we will notify you at the point of collection, or as soon as practicable, to ensure that you are aware of such collection and its purpose.
If someone other than you provides us with personal information about you, the notification will usually be provided to you via that third party. These third parties may include:
- other companies within the Spiire Group;
- our agents, contractors and external service providers (for example, mailing houses, payment systems operators and technology service providers); and
- contractors, designers, and developers for the App or the Website.
We will not disclose your personal information to overseas organisations unless required to by law or with your specific consent, or where you access the services, the Website or the App from outside Australia.
5. Direct Marketing
We may use personal information about prospective, current and past clients for the purpose of direct marketing of our products and services. Direct marketing communications may be sent via post, e-mail, telephone, social media sites or other means. However we will give you the opportunity to opt out of receiving further direct marketing communications from us.
You may opt out of receiving direct marketing communications from us at any time by contacting us using the details provided below.
7. Storage and security
We keep records of the personal information we gather from you including storage in WordPress. You warrant that you will only use the App and the Website in accordance with the terms and you will not use the service in a manner that results in us collecting, using or storing information that is in breach of our obligations at law.
We use all reasonable endeavours to keep your information in a secure environment and to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us using the details below. Where appropriate, your data will be encrypted and password protected. All connections to the services will be only available over SSL systems.
The WordPress storage system we use is accessible only by a limited number of people, and it is password protected with a firewall enabled.
If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy, securely delete, or de-identify your personal information as appropriate.
8. Accuracy of your information
We take reasonable steps to ensure that the personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us using the below details and we will take reasonable steps to correct it.
9. Variation and consent to variation
You will be deemed to have consented to such variations by your continued use of the App, the Website or our services following such changes being made.
10. Access to your information and making a complaint
You may request access to the personal information we hold about you. If you do so we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions provided under the Privacy Act. You may request this information by writing to our Privacy Officer.
Where it is practical to do so, when contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.
If you wish to make a complaint about a breach of the Privacy Act by us, you may do so by providing your complaint in writing to the contact details listed below. You may also make a complaint verbally. We will seek to respond to any complaint within a reasonable period of time. We may seek further information from you in order to provide a comprehensive and complete response.
You may also make a complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the Australian Information Commissioner via telephone on 1300 363 992, by submitting a complaint or inquiry online at www.oaic.gov.au or by writing to the OAIC at GPO Box 5218 Sydney NSW 2001
11. Contact us
If you have any questions, or if you wish to contact us for any of the reasons described above, including to correct or access the information we hold about you or to make a complaint, please contact our Privacy Officer:
Spiire Australia Pty Ltd ACN 050 029 635
PO Box 16084 Melbourne VIC 8007 Australia