LUPARG Pty Ltd ACN 625 479 530 (“we”, “us”, “our”) are
committed to protecting your privacy. We understand that
users of our services and software products are
concerned about their privacy and the confidentiality
and security of any data that is provided.
This Privacy Policy sets out how we collect, use, store
and disclose
(Process) all personal
data, whether received through on of our websites
(Website), our software
products and solutions
(Software) or through our
general interactions with you.
We will only Process personal data in accordance with
this Privacy Policy, and the laws applicable in the
jurisdiction in which we are Processing that data. If
there is any inconsistency between this Privacy Policy
and an applicable law, the applicable law will prevail
to the extent of any inconsistency.
1.2 Contact
Our contact details are:
www.continusys.com
Telephone: +617 3184 4441
Post: LUPARG PTY LTD
Lobby 1, Level 2
76 Skyring Terrace
Newstead QLD 4006
Australia
Privacy Issues Email: support@continusys.com
2. Nature Of Personal Data
In this policy when we talk about "personal data" we are
referring to any information which can, directly or
indirectly, be used to identify you. For example, names,
addresses, personal identification numbers, location
data and other online identifiers (such as email
addresses).
2.1 Anonymised Data
Whenever you visit our Website, our servers
automatically record information for statistical
purposes about your usage of the Website such as:
The type of browser used;
The referring URL;
The IP address;
The number and type of pages viewed;
The date and time of visits; and
The exit URL.
This information we collect about you is not personal
data and, in any event, remains anonymous. We do not
link the anonymous information to any other personal
data and we will not link a record of your usage of our
Website to you personally.
2.2 Personal Data
When using our Software we ask you for certain personal
data to provide you with the products or services that
you request from us. This may include, for example, when
you create a user account in order to enable you to
access our Software services. We may also collect
personal data when you have made an enquiry or request
from us, or when you otherwise interact with us
generally (such as by telephone, in person or by email).
The nature of the personal data that we collect
includes:
Your contact details (full name, email,
telephone number and delivery and billing
address);
The name of your employer or place of
business;
Login and account information; and
Banking information (if this is being provided
by your personally and not by an employer or
organisation).
3. Cookies And Other Tracking Technologies
To improve your experience on our Website, we may use
cookies and other tracking technologies, such as pixel
tags, web beacons, device IDs, or advertising IDs.
You may refuse the use of cookies by selecting the
appropriate settings on your browser, however please
note that if you do this, you may not be able to use the
full functionality of our Website.
Our Website may use Google Analytics, a service which
transmits website traffic data to Google servers in the
United States. Google Analytics does not identify
individual users or associate your IP address with any
other data held by Google. We use reports provided by
Google Analytics to help us understand website traffic
and web page usage.
You can customise or opt out of Google Analytics for
display advertising using the Ads Settings for your
Google account.
Our Website uses cookies and other tracking technologies
to support Google Analytics for:
Google Marketing Platform integrations;
Demographic and Interest Reporting;
Display Advertising including Remarketing and
Google Display Network Impression Reporting to
advertise our services online;
Optimizing and personalizing ad services based
on your past visits to our Website; and
Reporting the use of ad services and
interactions with ad impressions and how they
are related to visits to our Website.
Cookies and other tracking technologies may also be used
to support analytics by other third parties.
4. Purposes Of Collecting, Holding, Using And Disclosing
Personal Data
4.1 Collect from you only
Where it is reasonable or practical to do so we will
only collect personal data about you from you directly.
If we collect personal data which we have not sought or
requested about you, and if we determine we are legally
permitted to collect that information, we will deal with
that information in accordance with the terms of this
Privacy Policy. In all other circumstances, we will
destroy or de-identify the relevant personal data as
soon as practicable, where it is lawful and reasonable
to do so.
4.2 Purposes of collecting Personal Data
We will only Process your personal data for the purposes
of:
Enabling us to provide you with our Software or
any other products or services that you have
requested;
Creating user accounts within our
Software;
Providing technical support or responding to
your general queries and enquires;
Our internal research and statistical
purposes;
Marketing our Software and related products and
services to you;
Enabling us to forward to you other information
or material which we genuinely believe may be of
interest to you;
Verifying and authenticating the payments to
us, or enabling a payment processor to process
payments that you make to us;
Enabling us to defend or prosecute a legal
proceeding, or to comply with the order of any
court or regulatory authority; and
Any other purpose specified in an agreement
that we enter into with you.
If we Process your personal data for any other purpose
other than that specified above, such use will relate to
the above purposes, and will be within what you would
reasonably expect us to use that personal data for at
the time of collection.
We do not sell personal data to any third parties or
provide personal data to third parties for any
business purpose (unless that business purpose has
been specifically referred to in this Privacy
Policy).
4.3 Direct marketing
From time to time we may use your personal data to
provide you with current information about special
offers you may find of interest, changes to our
organisation, or new products or services being offered
by us or any company we are associated with.
You consent to us using your personal data to
contact you on an ongoing basis for the purpose of
us marketing our Software and related products and
services to you, howsoever such advertising may
occur.
4.4 Withdrawing Consent
You may withdraw your consent to our use of your
personal data at any time by contacting us using the
contact information contained in this Privacy Policy.
However, this may affect or limit your ability to access
our Website or the services available through our
Software.
If you do not wish to receive marketing information, you
may at any time decline to receive such information. We
will take all reasonable steps to meet your request at
the earliest possible opportunity.
4.5 Holding of Personal Data
We will endeavour to use industry best practice
processes and take all reasonable steps to protect
personal data that we hold from:
Misuse, interference and loss; and
Unauthorized access, modification or
disclosure.
In the unlikely event that there is a serious data
breach that is likely to result in a risk to your rights
and freedoms, we will without undue delay notify the
appropriate supervisory authority in your jurisdiction.
Where there is a high risk that a serious data breach
will impact upon your rights and freedoms, we will also
notify you of that breach.
4.6 International Data Transfers
Typically, all personal data that you provide to us will
be processed within Australia.
However, in order to provide customer support, perform
back office functions, deliver Software products and
services to you, perform fraud prevention tasks we may
need to allow our staff or third party service providers
(who may be located in a location other than your
country of residence) access to your personal data and,
in particular, your name, delivery address and billing
information.
We will always ensure that the recipient of your
personal data offers an adequate level of protection,
for instance by entering into the appropriate
back-to-back agreements and, if required, containing the
standard contractual clauses for the transfer of
personal data as approved by the European Commission.
Such transfers are necessary for us to perform our
obligations and provide our products and services to
you.
Despite the above, by providing your personal data
you are explicitly consenting to the international
transfer and Processing of such data in accordance
with this Privacy Policy, in full and informed
knowledge of the risks associated with such
transfers and Processing.
4.7 Unsolicited information
You may withdraw your consent to the international
transfer of your personal data at any time by contacting
us using the contact information contained in this
Privacy Policy. However, this may affect or limit our
ability to provide you with our Software and associated
products or services.
5. Destruction Of Personal Data
We will keep your personal data only for as long as we
need it to fulfill our contractual obligations to you,
for our legitimate business purposes or as required by
applicable law. We will take reasonable steps to erase
any personal data that we hold about you where:
We no longer need the personal data for the
purposes for which it was collected and we are
not otherwise entitled to retain such data;
and
We are not required or obligated by law,
regulation or court order to retain the
information.
If certain information has been provided to third
parties in accordance with this Privacy Policy,
retention of that information will be subject to the
policies of the relevant third party
6. Access, Correction And Portability
6.1 Access to Personal Data
We will provide you with access upon request to the
personal data held by us in relation to you except to
the extent that:
Giving access would be unlawful; or
Denying access is required or authorized by or
under a relevant law, regulation or court
order.
To request access to your personal data, please contact
us using the details provided in this Privacy Policy.
Following your request, we will contact you within one
(1) month from the date of receipt of your request and
provide you with the personal data requested, unless we
have determined that some reason or obligation exists
requiring us to withhold access to the personal data.
6.2 Third party disclosure
We do not sell your personal data to any third parties.
Unless specifically referred to in this Privacy Policy,
we also do not disclose your personal data to any third
parties for other business purposes.
However, notwithstanding the above, you may at any time
request that we provide confirmation that your personal
data has not been sold to a third party, or to request
details of any third party to which information has been
sold or disclosed for business purposes.
We may in the event of a sale or a restructure of your
business disclose your personal data as part of
facilitating any transaction or restructure that we are
undertaking that involved a third party.
6.3 Data portability
Insofar as it does not adversely affect the rights and
freedoms of others and where you have communicated a
request to us:
Where we have employed an automated means to
Process your personal data, we will provide you
with a copy of such personal data in a
structured, commonly used and machine -readable
format; and
After receiving your request, where technically
feasible, we will transmit your personal data
directly to another data holder.
6.4 Commercially sensitive information
Where providing you access to your personal data would
reveal commercially sensitive information, we are unable
to give you access to that information. However, we will
provide you with the reasoning behind our determination.
6.5 Use of intermediaries
Where we cannot directly provide you with access to your
personal data we may, if it is reasonable, engage the
services of an intermediary to do so.
6.6 Correction and erasure of Personal Data
It is your responsibility to ensure that the information
you provide to us is accurate, and to update your
personal data as necessary.
If for any reason you are unable to correct any personal
data held by us through your user account in our
Software, please contact us using the details provided
in this Privacy Policy.
If after receiving your request we choose not to correct
your information, we will notify you within one month of
the reason of our refusal and the mechanisms available
to you to object to our refusal.
If you wish to have your personal data erased, please
communicate your request to us using the contact
information provided above. The only circumstances in
which we will not take reasonable steps to erase your
personal data are where we need to keep it in accordance
with another provision of this Privacy Policy, an
applicable law, or the order of a court or regulatory
authority.
If we correct or erase personal data about you that we
previously disclosed to a third party, we will take
reasonable steps to notify the third party of the
correction or erasure and to request that they do the
same.
6.7 Refusal to correct or erase
If at any time we refuse or deny you access to your
personal data, or refuse to correct or erase your
personal data, we will provide you with reasons we are
unable to satisfy your request.
6.8 Restriction of processing
You may request that we limit or restrict the manner in
which we Process your personal data, in which case we
will only Process your personal data: with your consent;
for the establishment, exercise or defence of legal
claims against us; or for the protection of the rights
of another person.
6.9 Costs
Access to, erasure and rectification of your personal
data, including any communications related thereto, will
generally be provided free of charge.
Where your requests are manifestly unfounded or
excessive in nature (particularly due to repetitiveness)
we may charge you a reasonable fee for providing the
information or communication, or taking the action
requested. Where your requests are manifestly unfounded
or excessive in nature we may also refuse your request.
6.10 Specific objection rights
If it becomes necessary for us to Process your personal
data without your consent for reasons of:
Performing a task in the public interest;
The exercise of an official authority that has
been vested in us; or
Where it is in our legitimate interests or the
legitimate interests of a third party to do
so;
You will have the right to object to such use.
We will notify you of such instances. If you object to
our use of your personal data we will refrain from using
your personal data unless compelling legitimate grounds
exist for us to use that personal data, or for the
establishment, exercise or defence of legal claims.
If we have collected your personal data in accordance
with this Privacy Policy and elect to use such personal
data for the purposes of direct marketing (to which you
consent), you have the right to object at any time to
such use. Upon receiving an objection we will, as soon
as is reasonably practical, cease using your personal
data for the purposes of direct marketing.
7. Complaints
7.1 Making a complaint
If you believe that we have used or disclosed your
personal data in a manner which is contrary to this
Privacy Policy or that otherwise breaches an applicable
law, then you should email us at
support@continusys.com
You also have the right to lodge a complaint with the
relevant supervisory authority in your jurisdiction. If
you are unsure who your relevant supervisory authority
may be, please contact us so that we may provide you
with assistance.
7.2 Our response
Within 30 days of receipt of your complaint we will
notify you in writing as to what action we propose to
take in relation to your complaint and will provide you
with details of what further action you can take if you
are not satisfied with our response.
8. Variations
We reserve the right to vary this Policy from time to
time. Any variations made will be updated on our
Website. It is your responsibility to check our Policy
periodically to ensure you are aware of any changes made
to it.
9. Further Information
For any further information about this policy please
contact us be
support@continusys.com
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