Privacy Policy

 

Indigo8 Corporate Services Pty Ltd (ABN 91 620 108 170) and its related bodies corporate (together “Indigo8” or “We/we” or “Our/our” or “Us/us”) is committed to respecting the privacy of your personal information.

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (the “Collection Channels”):

  • our online properties (each, a “Website”), including:

    • our websites, including, but not limited to http://www.indigo8services.com.au/

    • any of our related websites, social media pages, internal websites; and

    • any Indigo8 mobile or tablet applications;

  • any other means through which you provide personal information to us, including either physically or electronically;

  • any National Police Checking Service application/consent form provided to us by you or your applicants, , including either physically or electronically; and

  • any other means through which we lawfully collect personal information about you.

You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting Indigo8’s privacy officer via email: theprivacyofficer@indigo8services.com.au or telephone: 02 9055 5400.

 

GENERAL

 

1. We are committed to safeguarding personal privacy. We recognise that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below.

2. Throughout this Privacy Policy, we refer to your 'personal information', which means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address, drivers licence details, passport details and workplace/employment contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences or any additional information as required by the national police checking service.

3. Indigo8 has developed and implemented its Privacy Policy with respect to personal information to reflect best practice on privacy policies in accordance with the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles.

4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.

5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

 

ANONYMITY AND PSEUDONYMITY

 

6. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below. It will not be practicable to deal with you on an anonymous or pseudonymous basis if:

a. you wish to have a national police check undertaken

b. when we wish to send you direct marketing materials or need to provide you with products or services requested by you.

 

KINDS OF PERSONAL INFORMATION THAT INDIGO8 COLLECTS AND HOLDS

 

7. Personal information that may be requested includes, but is not limited to:

a. contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;

b. more detailed contact preferences including your workplace contact details;

c. your gender;

d. location information;

e. personal identification numbers such as driver’s licence and/or passport number;

f. utility service provider identification number;

g. your occupation and information regarding your professional history and professional interests;

h. information regarding your personal interests and interesting and relevant information about you;

i. financial details including your bank account and credit card details;

j. your online behaviour and interests based on your online browsing activity;

k. demographic information such as age group and preferences;

l. information about your preferences, interests, and experiences with our products and services. This information is collected in order to tailor our communications to you and continuously improve our products and services;

m. information about your experience with our products or services or third party products or services, including products or services listed on a Website;

n. the contact details of third parties. If you are asked to provide details about other people, including applicants for the National Police Checking Service, please ensure that these individuals are happy for their details to be given to Indigo8 and used for the purposes set out in this policy; and

o. any other personal information which you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).

8. When you use a Website, we may also collect personal information about you in the following general categories:

a. usage and preference information: we collect information about how you interact with a Website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;

b. device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and

c. other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.

 

SENSITIVE INFORMATION

 

9. We will only collect sensitive information with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to, criminal history), we will only use this information for the purposes stated at the time of collection and will only share this information with our trusted third parties in the manner stated on the Website or in this Privacy Policy.

We may use sensitive information to perform a national police check. If we receive unsolicited sensitive information from the third-party Australian Criminal Intelligence Commission, we will destroy and/or de-identify the information in a timely manner in accordance with legal requirements.

 

HOW INDIGO8 COLLECTS AND HOLDS PERSONAL INFORMATION

 

10. We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties.

 

ACTIVE INFORMATION COLLECTION

 

11. Personal information may be collected (and combined) via our Collection Channels if you:

a. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;

b. sign-up and/or register to become a member of any Collection Channel;

c. complete an application for the National Police Checking Service;

d. subscribe to any newsletters, updates, alerts or news and media releases, or request information about our products and/or services as well as third party products or services;

e. complete and submit any forms or applications to us;

f. place an order for or agree to use our products and/or services;

g. contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;

h. participate in any offers, promotions, competitions, rewards or marketing activities;

i. interact with a Website for a specific purpose;

j. interact with or browse a Website generally; or

k. make a complaint to us.

 

12. Personal information is requested in order to facilitate or provide you with certain content, products or services, National Police Checking Service and information about such content, products or services (including offers made available via our Collection Channels), , newsletters, electronic newsletters (e-newsletters), news and media releases / launch information.  No one is obligated to provide personal information. However, failure to do so may result in Indigo8 being unable to facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, offer or event information or other content from you (where applicable).

 

13. We may also obtain your personal information from legitimate third party sources and platforms including social media channels, commercial data providers, referral agents, marketing companies, targeting companies, list brokers and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so, including our service providers. For example:

a. we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area; and

b. we may obtain third party information relating to your advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular advertisement.

 

CHILDREN

 

14. Personal information will not be collected by any person who is known by Indigo8 to be under the age of eighteen (18) without the consent of a parent or legal guardian. Persons under age eighteen (18) may only use our Websites with the involvement and consent of a parent or legal guardian.

 

PASSIVE INFORMATION COLLECTION

 

15. As with many commercial websites, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information. When you receive newsletters or e-mails from Indigo8, we may use web beacons (described below), customised links or similar technologies to determine whether the e-mail has been opened and which links you click in order to provide you with more focused e-mail communications or other information.

16. As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (“UDI”), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth). This is dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the Website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (“IP”) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.

17. Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.

18. For more information about cookies and how you can opt out, you can visit more information about cookies and how you can opt out, you can visit https://www.oaic.gov.au/privacy/your-privacy-rights/advertising-and-marketing/targeted-advertising/.

 

PLATFORM PERMISSIONS

 

19. Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining your consent. For example, the iOS platform generally alerts you the first time an Indigo8 app wants permission to access certain types of data, such as location services, and will let you choose if to consent to that request. Android devices will generally notify you of the permissions that an app seeks before you first use the app, and your use of the app constitutes your consent. You can generally manage your platform level permissions via the Settings section on your device. For more information, please contact our Privacy Officer at the details set out in this policy.

 

PURPOSES FOR WHICH INDIGO8 COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

 

20. Personal information collected will be used for the following primary purposes:

a. For the purposes stated in a privacy collection statement on a particular Collection Channel.

b. To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.

c. To market products or services related to Indigo8, our clients, suppliers, promotional partners and trusted third parties.

d. To respond to customer enquiries, complaints and complaints handling.

e. To send you any technical, administrative or legal notices important to our Websites.

f. To allow you to respond to and participate in offers and competitions.

g. To conduct competitions or promotions and communicate offers either for us or trusted third parties.

h. For internal record keeping including site usage, maintaining databases and administration of our products and services.

i. To process applications for our clients, suppliers and trusted third parties’ services.

j. To process donor pledges for charitable organisations.

k. To provide you with information about your transactions, content, services and products.

l. To provide direct marketing materials, events, offers, competitions and promotions, from Indigo8 or third parties, in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel for us and our clients, partners, suppliers and trusted third parties.

m. To provide you with relevant advertising when you use our Websites or those of a third party.

n. To share reviews or testimonials provided by you.

o. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.

p. To improve Website and system administration.

q. To obtain opinions or comments about products and/or services and to conduct other research and development.

r. To verify your identity.

s. To investigate complaints made by you.

t. To record statistical data for marketing analysis and to conduct market research.

u. To share, license or sell personal information with our service providers, promotional partners, and other trusted third parties (and their directors, servants, agents and contractors) in the manner described below.

v. Any other purpose as may be deemed reasonably necessary by Indigo8 in the circumstances.

 

21. Additional to point 20 above, personal information collected via a National Police Checking Service Application will be used:

a. To lodge an application for and receive the results of a national police check through the National Police Checking Service.

b. To provide the results of a national police check to any person you authorise us to.

c. For proof of identity.

d. To allow third parties you have agreed to allow access to the results of these searches for the purpose of verifying the contents of a national police check.

e. To comply with our obligations under any agreement Indigo8 has with the Australian Criminal Intelligence Commission regarding the National Police Checking Service.

 

22. For the purposes described above, personal information may be shared with selected Indigo8 service providers, promotional partners and their related bodies corporate, and other trusted third parties (and their directors, servants, agents and contractors) in Australia. Failure to provide personal information may result in Indigo8 being unable to provide you with certain services, content, information, upcoming opportunity, promotion, offer, event or product information and/or accept content (where applicable).

23. In order to operate a Website, deliver a product or service, undertake National Police Checking Services or administer your donor pledge, personal information may also be shared with our selected service providers and their related bodies corporate, and/or other trusted third parties in Australia. Indigo8 selected service providers and/or other trusted third parties may be engaged by or contracted to Indigo8 to perform a variety of functions or services, such as list broking services, product marketing services, data pools, completing order forms, procuring applications for our clients, procuring donor pledges, email systems providers, legal and accounting services, data storage, fulfilling orders and providing client services, conducting market research, processing credit card payments, assisting with promotions or offers and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions.

24. We recognise the trust with which you provide personal information, and except as stated in this Privacy Policy or as is otherwise lawful, such information will not be used or disclosed for any other purposes without consent. However, Indigo8 reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Indigo8, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

 

NATIONAL POLICE CHECKING SERVICE AND INDIGO8

 

25. Indigo8 undertakes criminal history checks in alignment with the requirements set by the National Police Checking Service. If you complete an application for a national police check either directly with us or via an organisation you have authorised to request the national police check on your behalf, you will be requested to provide Indigo8 consent to undertake a national police check and to receive the national police check results.

 

If you do not provide us with your personal information, we will not be able to conduct the national police check. Any personal information provided by you for a national police check will be used for this purpose only, however we may also use your personal information in compliance with legislative or regulatory requirements.

CONTACT BY INDIGO8

 

26. Indigo8 (and its directors, servants, agents and contractors), our promotional partners or trusted third parties (and other selected service providers and or professionals) in Australia may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the purposes for collection of personal information as stated above.

27. We do not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or as is otherwise lawful to do so. If you receive communications from us which you do not wish to receive, you may remove your name from the database in the manner indicated in the communication, including by utilising the functional unsubscribe/opt-out facility (if the communication is via commercial electronic message) or by contacting us at the contact details in this Privacy Policy. Please allow 30 days for this request to be processed.

28. Despite removing your name from the database from receiving future advertising and marketing information, we may send you non-commercial “Administrative Emails”. Administrative Emails relate to a user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular user account.

 

ABILITY OF OTHERS TO VIEW INFORMATION

 

29. We may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services, utilise functionalities that allow you to post content to your own social media channels, or interact with particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. Reviews and testimonials that you upload to our social media platforms may be shared on our Websites, including without limitation, other social media platforms and other public forums and may also be published in promotional materials including but not limited to emails, point of sale material and flyers. This information may become publicly available and may be read, collected and used by others either on our Websites or outside of our We are not responsible for the conduct of others who may read, collect and use this information.

YOUR RIGHT OF ACCESS

30. You have the right to access and review your personal information that may be recorded on our database. Information may be reviewed by contacting our privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.

 

CHANGING AND DELETING THE INFORMATION WE HAVE ABOUT YOU

 

31. Information contained on the database may be amended, or your preferences for contact from us changed, by contacting our privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.

32. In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.

33. We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy.

 

STORAGE AND SECURITY OF PERSONAL INFORMATION

 

34. Indigo8 will endeavour to take all reasonable steps to keep secure any personal information recorded and to keep this information accurate, up to date, complete and relevant. We implement appropriate technical and organisation measures to help protect the security of personal information; however, please note that no system is ever completely secure. We have various policies and/or processes including but not limited to; pseudonymisation, encryption, access and retention policies to guard against unauthorised access and unnecessary retention of personal information in our systems.

 

35. The personal information we collect in relation to you or your applicants is stored in various ways, including in electronic form using third party data storage providers. All information that is stored electronically is password protected on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers.

 

36. We ensure only those necessary have access to your personal information. We aim to ensure that all personal information is securely protected from misuse, loss and unauthorised access, modification or disclosure by way of maintaining:

a. physical security by preventing unauthorised access to our premises;

computer network security, including password security to prevent unauthorised access;

b. communication security; and

c. limiting access to personal information to authorised personnel of Indigo8

When personal information is no longer needed, we take all reasonable steps to destroy and/or de-identify that information.

INDIGO8 AND LINKS TO OTHER WEBSITES

 

37. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Indigo8 is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.

38. We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Indigo8 or any of its affiliates. Indigo8 is not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

 

RELATED INDIGO8 WEBSITES

 

39. All Websites operated by us will adhere to this Privacy Policy.

 

SALE OF THE COMPANY

 

40. If our company merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

Sensitive information obtained via National Police Checking Service is exempt from this disclosure.

 

PROBLEMS OR QUERIES

 

41. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:

 

Address: The Privacy Officer

Indigo8 Corporate Services Pty Ltd

Suite 2, Level 2, 61 Dunning Avenue

Rosebery NSW 2018

Telephone: 02 9055 5400

Email: theprivacyofficer@indigo8services.com.au

 

Please allow 30 days for this request to be processed. On receipt of your complaint a review will be conducted, and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at https://www.oaic.gov.au/about-us/contact-us/.

 

CHANGES TO THIS STATEMENT

 

Indigo8 may make changes to this Privacy Policy from time to time for any reason. We will publish those changes on our website www.indigo8services.com.au. For more information please email theprivacyofficer@indigo8services.com.au.