Way We Do Privacy Policy
Last Modified: 13 October 2017
1. Privacy Statement
Keyword Intent Pty Ltd ACN 138 544 555 trading as Way We Do (we, us, our) consider your privacy, that of your authorised users and clientele important to us. We understand that you are concerned about privacy, along with the confidentiality and security of any personal information that you provide to us. We take our responsibility to protect it seriously.
This Privacy Policy (Policy) sets out how we collect, hold, use and disclose personal information. We treat all personal information collected by us in accordance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles contained within the Privacy Act and this Policy.
If there is any inconsistency between the Privacy Act and this Policy, the Privacy Act will prevail to the extent of that inconsistency.
2. Personal information
Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. We collect a wide variety of personal information that is reasonably necessary for the purposes of conducting and improving our business and our services. This information is collected from a range of sources including:
(a) through our website www.waywedo.com and online application http://[company].waywedo.com (the Site);
(b) through our account creation process;
(c) directly from authorised users inputs into the Site;
(d) through marketing research;
(e) from conducting business or intending to conduct business with us, whether past, present or future;
(f) via surveys;
(g) by otherwise having some form of contact with us such as by mail, telephone, email, internet or intranet; and/or
(h) through any of our other business activities or events.
Personal information collected by us may include:
(a) your name;
(b) the organization that you represent and your position in it;
(c) your occupation;
(d) your contact details such as your mobile number, telephone number and email address;
(e) your reasons for using our services;
(f) your preferences and opinions;
(g) all of the above listed personal information relating to authorised users;
(h) any personal information about your clientele or prospective clientele that has been inputted into the Site via activated checklists and/or interactive procedures hosted by us; and
(i) all logs, which may include information such as your internet protocol (IP) address, browser type, browser version, clickstream data, referring URLs, the pages of our Site that you visit, the time spent on any pages of our Site and other log related information relating to your use of our Site (Logs).
3. Use of personal information
We automatically gather information to monitor the use of our Site. Much of the data we collect is aggregated, and this information is effectively anonymous to us.
Sometimes you will be asked to confirm that you agree to a particular activity, or the collection of personal information for a specific purpose. It will be made clear if any information is being collected in a way that could personally identify you.
In general we use personal information for marketing, evaluating and improving our business, our Site and our services. More specifically we use personal information for:
(a) improving user satisfaction by automatically analysing your Logs and sending relevant site internal messages to you automatically;
(b) providing support to you;
(c) promoting and marketing our Site to you (each person may opt-out of marketing and sales communications) including by tele-marketing;
(d) determining whether an individual is suitable for a position within our business, as an employee or contractor for a current or future project;
(e) our internal research and statistical purposes (including market segmentation, market analysis and trend identification); and
(f) enabling us to forward to you other information or material which we believe may be of interest to you (each person may opt-out of our information sharing communications).
4. Disclosure of personal information
We do not disclose personal information to any third party without consent, except where that third party requires the information to assist us in an advisory, technical or services context. This includes providing your personal information to partners within our partnership program so that they can provide you with support.
Aside from the above, we will only disclose personal information as legally required – either upon valid court order, as required under the Privacy Act, or where compelled by a law enforcement or governmental agency.
5. Protecting personal information
5.1 Steps we take
We take reasonable steps to protect personal information we hold from:
(a) misuse, interference and loss; and
(b) unauthorised access, modification or disclosure.
The precautionary steps we take to protect personal information includes:
(a) adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information;
(b) adoption of procedural and personnel measures for limiting access to personal information by our staff;
(c) reviewing the privacy policies of external parties that provide services to us;
(d) regularly reviewing our information collection, storage and processing practices; and
(e) such other security measures we consider reasonable and appropriate from time to time.
Notwithstanding that we use our best endeavours to protect all personal information we collect and hold, we unfortunately cannot guarantee its complete security.
5.2 De-identifying personal information
When personal information is no longer required, we will take reasonable steps to destroy or delete the personal information in a confidential manner.
All personal information we have collected that forms a part of our sales process is retained within our CRM system until it is no longer of any benefit to us with respect to onboarding.
All personal information that is contained within the Site as content, we endeavour to delete within 6 months of its last use.
6. Cookies
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive.
We use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some features of our products and services.
7. Overseas disclosure
7.1 No overseas disclosure
We store all personal information that we collect within the Site, including Logs, standard operating procedures and content you or your authorised users have input, on servers located in Sydney, Australia.
Subject to clause 7.3, we will not disclose or transmit any personal information we have collected overseas.
7.2 Disclosure for analytics
We may use analytics software to track usage on our Site. Analytics software utilises data collected to track and examine usage of the Site, to prepare reports on the Site’s activities and shares that information with other applications.
Google Analytics is the core external analytics application we use. Google Analytics may reuse the data collected to contextualise and personalise ads on its own advertising network. Personal data collected by Google includes cookie and usage data, which is processed in the USA. You can find Google's privacy policy here: http://www.google.com.au/policies/privacy/.
Should you wish to obtain any further information on our analytics applications and processes please let us know.
7.3 Consent to overseas disclosure
We will only disclose personal information to an overseas recipient if:
(a) you consent to the transfer;
(b) we have disclosed the information to CRM Capsule, Xero or other applications providing services to us in the general course of our business; or
(c) the disclosure of the information is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.
We will take reasonable steps to ensure all overseas recipients do not breach the APP’s and are subject to laws or a scheme substantially similar to the APP’s.
8. Third parties
Our website and products may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services whatsoever.
You should be aware that your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.
9. Accessing and updating personal information
9.1 Access to Personal Information
We will provide you with access to personal information held by us unless:
(a) giving access would be unlawful; or
(b) denying access is required under the Privacy Act or any other applicable law.
9.2 Request for Access
If you would like access to personal information aside from your account information, you must contact us in writing making such a request. Following receipt of your request, we will contact you and either provide you with the information you have sought, or an explanation detailing why we will not provide you with the information.
9.3 Amending personal information
We endeavour to keep all personal information we hold accurate, up to date and complete. If at any time you wish to correct any of your personal information or the personal information of any of your authorised users or clientele you may be able to do so via the site.
If you wish to amend personal information that we hold that is not editable, please contact us to request amendment. If we elect not to correct your information, we will notify you, within a reasonable time, detailing the reason for our refusal, the mechanisms available for
you to complain about our refusal and such other matters required by the Privacy Act.
If you wish to have your non-editable personal information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
10. International users
If you are located outside Australia and choose to provide personal information to us via the Site, that personal information will be transferred to Australia and processed in accordance with this Policy.
11. Complaints
We strive to ensure strict compliance with this Policy and to regularly review our practices against it.
If at any time you have a complaint against us regarding this Policy, including a breach of the Privacy Act, we invite you to make a complaint. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution to the issue raised.
Please note that you may also make a complaint to the Office of the Australian Information Commissioner about the handling of your personal information. Information on making a privacy complaint can be found here: http://www.oaic.gov.au/privacy/making-a-privacy-complaint.
12. Variations
We reserve the right to vary this Policy from time to time without further notice to you. Any variations made will be updated on our website. We will not make changes to this Policy that are detrimental to your position without providing you with prior notice.
It is your responsibility to check our Policy every now and again to ensure you are aware of any changes made to it.
13. Contact us
You may contact us at any time regarding this Policy by emailing support@waywedo.com.