Definitions and Interpretation
“Software” means the Website and all related sites, applications, services and tools.
“Us”, “we”, “our” or “SPF Pty Ltd” means SPF Pty Ltd Pty Ltd ACN 163 197 028.
“User” or “you” means a user of the Software.
“Website” means SPF Pty Ltd’s Starting Block Business Consultants website at http://www.startingblock.com.au/
SPF Pty Ltd is not currently bound to comply with the Australian Privacy Principles and nothing in this policy shall be read to impose any obligation beyond that set out in this policy.
How we collect information about you
When you use the Software, we collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you’re using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you’re using and traffic to and from the Software. When you visit the Website we may also collect information about your transactions and your activities.
In addition, if you create an account on the Website, we may collect the following types of information:
- Contact information, such as your name, address, phone, email and other similar information.
- Detailed personal information such as your date of birth, country of residence, country of birth, or other personal identifiers.
We may also obtain information about you from third parties such as credit bureaus, payment processors and identity verification services.
You may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site.
In order to help protect you from fraud and misuse of your personal information, we may collect information about your use and interaction with the Software. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity.
We may also collect additional information from or about you in other ways, such as through contact with our customer support team, results when you respond to a survey and from interactions with the Software.
When you access or use the Website, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, or other local storage provided by your browser or associated applications (collectively “Cookies”). We use these Cookies to:
- identify you as a User;
- enable functionality on and to customise the Website or the Software, content, and advertising;
- measure promotional effectiveness;
- mitigate risk and prevent fraud; and
- to promote trust and safety on the Software.
We use both session and persistent cookies. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We encode our cookies so that we can interpret the information stored in them. You are free to decline our Cookies if your browser or browser add-on permits, but doing so may interfere with your use of Software. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling Cookies.
How we protect and store personal information
We store and process your personal information on our servers in Australia and elsewhere in the world where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.
How we use the personal information we collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. We may use your personal information to:
- provide the Software and customer support;
- facilitate transactions and send notices about your transactions;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent potentially prohibited or illegal activities, and enforce our terms and conditions;
- customise, measure, and improve the Software;
- deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
- contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorised by our terms and conditions; and
- compare information for accuracy and verify it with third parties.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalise the Software, content, and advertising. If you do not wish to receive marketing communications from us you may opt-out at any time by using the unsubscribe or opt-out feature contained in the communication that we send you.
How we share personal information with other SPF Pty Ltd users
We work with third parties, including payment gateways, payment processors to enable them to accept or send payments from or to you. In doing so, a third party may share information about you with us. This may include information to confirm that payment has been processed, and the transaction details, but not any credit card information. We use this information to confirm that a transaction has been completed and to record the details of that transaction.
How we share personal information with other parties
We may share your personal information with:
- Service providers under contract who help with our business operations such as fraud prevention, bill collection, marketing, and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to SPF Pty Ltd or one of its affiliates; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Website Terms and Conditions.
- Other third parties with your consent or direction to do so.
Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in Australia. However, we will take reasonable steps to ensure the third parties do not breach the Australian Privacy Principles in relation to the personal information.
SPF Pty Ltd will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described in this policy.
How you can access or change your personal information
You can review and edit your personal information at any time by contacting our Privacy Officer at firstname.lastname@example.org
How you can contact us about privacy questions
Handling your complaints
We aim to:
- Acknowledge receipt of all complaints within 5 business days.
- Resolve all complaints within 60 days. This may not be possible in all circumstances.
Where we cannot resolve a complaint within 60 business days, we will notify you of the reason for the delay as well as an indication of when we expect to resolve the complaint.