SixPivot Pty Ltd ABN 59 606 416 693 and its products “Cloud Ctrl”(‘we’, ‘our’, ‘us’) regards personal privacy and payment security as an important part of our relationship with our customers and users.
In this policy 'personal information' means 'information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether the information is true or not or recorded in any form or not)'.
Kinds and Collection of Personal Information
If you personally create a Cloud CTRL customer account (‘Account’) on our website, we need to collect and therefore require you to provide a range of personal information including your name, address, email address, phone number, mobile telephone number, date of birth, gender, your Cloud CTRL username and password, and financial information such as credit card or bank account details, and credit or transaction history. This is not an exhaustive list, and we also collect personal information you include in emails or other correspondence you send to us.
In addition to collecting personal information via our website, we may collect personal information in the following ways:
- by telephone or other means of communication with you or your company (including by email, mail or fax);
- through your use of our website;
- from third parties such as our related entities, business partners, credit reporting bodies, other clients and your representatives;
- from publicly available sources of information; and
- from our records of how you use our products or services.
While you can choose to deal with us or access some features on our website anonymously or using a pseudonym, you may be asked to provide certain personal information when using interactive areas of the site. Generally, you have no obligation to provide any information requested by us. However, if you choose to withhold the requested information, we may not be able to provide you with the products and services that depend on the collection of that information.
Using our website
- each page of the website visited;
- your server address;
- the type of browser you are using;
- your operating system;
- your top level domain name;
- the date and time that each page is accessed; and
- documents that you download.
Search terms that you enter when searching our database engine are collected, but are not associated with any other information that we collect, hence the user is not identifiable. We use these search terms to ascertain what users are looking for on our website, and to improve the services that we provide, as well as for the purpose of statistical usage analysis or systems administration.
This Policy applies to the domain name of www.cloudctrl.com.au and https://portal.cloudctrl.com.au/only. It does not apply to, and we are not responsible for, the use of, or the protection of information provided to, other websites linked to our website.
Use and disclosure of Personal Information
We use the personal information we collect to provide our customers and users with a high level of service. In particular, we use personal information:
- to verify your identity, or to conduct appropriate checks for credit-worthiness;
- to administer, deliver, manage and improve the products and services we provide;
- to ensure only one Account is created per customer;
- to deal with queries from users and customers;
- to facilitate Account registrations and the purchase of online services and to contact you if we have trouble processing a request;
- for billing and payment processing;
- to collect any amounts you may owe us, to pay any amounts you owe to third parties on your behalf, or to conduct or facilitate any financial or other transactions as part of or in connection with any products or services we provide to you; and
- to gain an understanding of your information and communication needs, and to perform research and analysis for the improvement or development of our products and services.
We may also use your personal information for the purpose of displaying or publishing advertising on web pages that you access or for sending you advertising and promotional material we think might be of interest to you. By submitting your contact details through our website, you consent to us displaying or sending such material to you. For material that we email to you, we provide a functional opt out facility with all promotional emails. You can let us know if you no longer wish to receive this sort of information by emailing us at firstname.lastname@example.org and we will remove your details from the distribution list.
We may disclose personal information to our related entities, third party service providers (including IT service providers, data storage and handling facilities, payment systems operators, mail houses and legal or financial advisers) to the extent necessary for them to assist us in providing services to you. We require our service providers to adhere to strict confidentiality requirements and all applicable privacy laws, and not use or disclose your personal information for any purpose other than the services for which they are engaged to provide.
We may disclose personal information to other persons or organisations if required to do so by the order of a court or tribunal or if the disclosure is otherwise authorised or required by law. For example, personal information may be disclosed where it is necessary to eliminate or minimise a risk to public health or safety, investigate or deal with unlawful activity or serious misconduct or establish or defend a legal claim.
We generally do not disclose personal information to persons outside Australia. However where you pay for services using a personal credit card, your personal information is likely to be sent outside of Australia (mainly to the USA) for processing by Stripe.com. We may also disclose personal information to third parties (such as our service providers) located overseas if such disclosure is necessary for us to provide products and services to you. The overseas countries to which we disclose your personal information depends mainly on where the third party service providers selected by you are located.
Storage of Collected Information
The security of your personal information is important to us. When you provide personal information (including credit card details) on our website, we encrypt that information using secure socket layer technology (SSL). When credit card details are collected, we simply pass them on in order to be processed as required. We never permanently store complete credit card details.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
Your personal information may be stored electronically or in paper files, in storage facilities that we own, operate or control ourselves, or that are owned or operated by our contractors or service providers. In addition to the above specific security measures regarding data transmission, we take reasonable steps to maintain the security of your personal information and to protect it from misuse, interference and loss, as well as from unauthorised access, modification or disclosure. The security measures we take include:
- storing your personal information in a secured environment;
- strictly allowing access to the secured physical storage facility by authorised personnel only;
- strictly allowing access to the secured electronic system on which your information is stored by authorised personnel only; and
- monitoring and tracking details of any access and/or change to your information, including the date and time at which your information is accessed and/or changed, and by whom.
If you have any questions about security on our Website or the security of your personal information collected and held by us, you can email us at email@example.com
Access to and correction of Personal Information
We take all reasonable steps to ensure that personal information collected, used and disclosed by us is accurate, up to date and complete. We will promptly correct any inaccurate information when identified.
Subject to any legal restrictions, we will let you know what personal information we hold about you if you ask us to. If your request is particularly complex, or requires detailed searching of our records, there may be a cost to you in order for us to provide this information.
If you believe there are errors in our records about you, please let us know and we will investigate and correct any inaccuracies.
All requests for access to personal information held by us should be made to firstname.lastname@example.org
Complaints and further information
If you believe your privacy has been interfered with and wish to make a complaint, please contact our Privacy Officer. The Privacy Officer will investigate your complaint and notify you of the outcome. If your complaint indicates that there has been an interference with your privacy by a person other than us, the Privacy Officer may discuss the complaint with that other person in an attempt to resolve it.
If you are not satisfied with the outcome of your complaint or the way we handle it, you may make a complaint to the Office of the Australian Information Commissioner at www.OAIC.gov.au/privacy/making-a-privacy-compliant.
Credit Reporting Policy
We may provide business or commercial credit (including but not limited to extended payment terms) to our customers in connection with our services. As a result, we may collect credit information and credit eligibility information (credit-related information) about you as referred to in the Privacy Act 1988 (Cth) (“Act”). This Credit Reporting Policy relates to us and to our related entities that are deemed to be credit providers for the purposes of the Privacy Act, and sets out how we manage credit-related information about individuals. It does not apply to the collection or use of credit-related information about corporations.
How we collect and hold credit-related information about you
Primarily, we collect credit-related information about you directly from you, and from your business dealings with us (including but not limited to any credit-related information provided to or derived by us in the normal course of operation of your Account).
Since we only provide business or commercial credit (rather than consumer credit) as part of our business, we do not hold an Australian Credit Licence (“ACL”) under the National Consumer Credit Protection Act 2009 (Cth). We are also not a member of a recognised external dispute resolution scheme (“EDR”). As such, we will only collect credit-related information about you from third parties if such collection is permitted by the Privacy Laws and with your consent, if such consent is required under the Privacy Laws).
How we use and when we disclose your credit-related information
As a provider of business or commercial credit only, a non-holder of an ACL and a non-member of an EDR, we will not use your credit-related information or disclose any such information (including any disclosure to any credit reporting body) if such use or disclosure is prohibited by the Privacy Laws.
Our use and disclosure of credit-related information is regulated by Part IIIA of the Act and the Credit Reporting Privacy Code. We will only use or disclose such information for purposes permitted by these laws, such as:
- processing credit-related applications and managing credit that we provide;
- assisting you to avoid defaults;
- collecting amounts you may owe us in relation to such credit and dealing with serious credit infringements;
- assigning our debts;
- dealing with complaints or regulatory matters relating to credit or credit reporting; and
- as required or authorised by another law.
We generally do not disclose any credit-related information about you to persons outside Australia. However where you pay for services using a personal credit card, we may disclose your credit-related information to Stripe.com located in the USA for one or more of the purposes listed above.
How to access or correct your credit-related information
We may apply an administrative charge for providing access to your credit-related information, depending on the request.
How to make a complaint regarding our compliance with Part IIIA of the Privacy Act and the Credit Reporting Privacy Code
We will acknowledge your complaint in writing as soon as practicable within 7 days. We will aim to investigate and resolve your complaint within 30 days of receiving it. If we need more time, we will notify you about the reasons for the delay and ask for your agreement to extend this 30 day period (if you do not agree, we may not be able to resolve your complaint).
While we hope that we will be able to resolve any complaint without the need to involve third parties, if you are not satisfied with the outcome of your complaint you can make a complaint to the Australian Information Commissioner (www.oaic.gov.au).
Changes to Credit Reporting Policy
We reserve the right to modify this Credit Reporting Policy at any time, so please review it frequently. If we make material changes to it, we will notify you by email or by means of a notice on our homepage.