Privacy policy

Protection of your personal information is important to SharePass. 

The way in which  SharePass Pty Ltd (ACN 647 015 601)  (“we”, “us”, “our”) collect, use, store and disclose personal information in accordance with our obligations under the Privacy Act, including those contained in the Australian Privacy Principles (APP) is set out below. 

This Privacy Policy also constitutes a collection statement for the purposes of the Privacy Act. Privacy Act means the Privacy Act 1988 (Cth) including the APP (as amended from time to time).

Personal Information has the meaning given under the Privacy Act but, in short, means information or an opinion relating to an individual that can be used to identify that individual.

By visiting the Website, downloading our Application(s), and/or otherwise accessing and/or using our Service, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of service, which incorporate this Privacy Policy and the Permitted Use Policy and Cookies Policy by reference.

Capitalised terms not defined in this Privacy Policy shall have the meanings set forth in the Terms of service.

This Privacy Policy applies to information we collect through any version of the Service and to information you send to us. It does not apply to information collected by any third party, including through any application, content, link or other interaction that may be accessible to you through the Service.

We only collect information that is reasonably necessary for the proper performance of our activities or functions and Services.  We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it.  We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.

We manage personal information as if we are an APP Entity under the APPs.

What Personal Information do we collect and why do we need it

To provide you with access to the Website, Application and our Services, we need to collect Personal Information.  If any of the Personal Information you provide is incomplete or inaccurate, we may be unable to provide Services to you or the quality of those Services we provide may be compromised. If you do not agree, you may not use the Service.

The nature of the relationship we have with you and the Service you require from us will determine the personal and other information we collect. 

Accordingly: 

  • we determine that it is reasonably necessary for our functions or activities in respect of the Service being provided; 
  • we attempt to cross-check the information that we collect from you with third parties;
  • we record and hold your information in our Systems. Some information may be disclosed to third party or overseas recipients;
  • we retrieve your information when we need to use or disclose it for our functions and activities as relevant to our Service;
  • subject to some exceptions, we permit you to access your Personal Information in accordance with the APPs.
  • we correct or attach associated statements to your Personal Information in accordance with the APPs.

Personal Information may include:

  • contact and identity information (for example, your name, email address, telephone numbers, address, social media handles, date of birth and educational qualifications and similar information or other information in a registration form);
  • Personal Information (including Sensitive Information) which is provided to us in the course of Services by us to you or a third party;
  • data stored in the address book on the Device from which you are accessing and using the Service (but processed in hashed/anonymised form (i.e., in a manner in which we cannot read the data);
  • temporarily process and store your Message (in encrypted form), log and contact data, and other related information (we do not (and cannot) read your encrypted Messages, and we delete your Messages as soon as they have been successfully read or, in the case of an unread message, after several days have elapsed;
  • your IP address, operating system and language, information about your Device, including Device model and manufacturer, universally unique ID and/or mobile advertiser ID, screen size and resolution, carrier and network status, country and time zone, storage and processor information;
  • bank details and expiry dates;
  • feedback that you may have provided.

“Sensitive Information” has the same meaning as under the Privacy Act.

How do we collect Personal Information?

We aim to collect Personal Information directly from you electronically through our website. 

However, we may also collect Personal Information about you when we, for example: 

  • provide our Services to you; and
  • receive performance feedback (whether positive or negative) from any person.

We may also collect Personal Information:

  • from automated data collection technologies;
  • from parties to whom we refer you;
  • from credit reporting and fraud checking agencies;
  • from debt collection agencies if you default in a payment to us;
  • through our website and by other electronic communication channels;
  • any third-party applications;
  • from your spouse, partner or dependants;
  • from third parties;
  • from publicly available sources of information (including but not limited to newspapers, journals, directories, the Internet and social media sites);
  • when we are permitted or required to do so by law (including under the Privacy Act).

If you, your friends, or members of your network use any third-party applications, you consent to those applications accessing and sharing certain personal information about you with others in accordance with your privacy settings. We do not screen or approve developers of applications and cannot control how those developers use any personal information that they may obtain in connection with applications.

How do we use your Personal Information?

We use the Personal Information we collect, hold use and disclose for the purpose of providing our Services.

We may also use Personal Information:

  • to comply with our contractual and other legal obligations (including but not limited to customer support and information on our Services, newsletters email updates, subscriptions and other services);
  • to verify your identity, including during account creation and password reset processes and to pursue other activities within our legitimate interests as part of running our business and doing so in ways which do not hurt your interests and rights, for example obtaining identity, device and location information to prevent fraud and abuse and to keep the applications secure and obtaining and retaining data which tax laws require us to retain for payments made or received by us;
  • to confirm your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and assess applications or creditworthiness for premier or business accounts or products and services offered to premier or business accounts with third parties;
  • to customise, measure, and improve the content, layout, and operation of the applications and related services;
  • to contact you at any telephone number, or by placing a voice call or through text (SMS) or email messaging;
  • to manage and protect our information technology infrastructure, which is necessary to provide the services and features you request and serve the legitimate interests of ourselves and third party processors;
  • to share minimal personal information and data with third party processors in order for us to provide services under our contract with you, including service providers of hosting, storage and infrastructure, security, insurance, analytics, communications and support, and payment processing;
  • to perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties;
  • to design new products and services;
  • to provide to you targeted marketing about our Services and promotional offers and the services of our contractors unless and until you opt-out;
  • to include you in our databases, directories, listings and digital applications to communicate with you and indicate your affiliation with us;
  • to process any transactions by you and send notices about your transactions;
  • to resolve disputes, collect fees, and troubleshoot problems;
  • to detect, prevent or resolve violations of policies or applicable user agreements; and
  • to manage our risks and help detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities.
  • for insurance purposes;
  • for statistical purposes and statutory compliance requirements;
  • for improving our client service, including customising our website in order to better suit your requirements;
  • for responding to enquiries or questions from you;
  • for training; 
  • for risk management
  • for any client and business relationship management;
  • to confirm identity and authority to provide references;
  • subject to you advising us otherwise (see Marketing below), to advise you of additional services or information which may be of interest to you; and
  • otherwise as permitted under the Privacy Act.

If you default in a payment to us, we may use your Personal Information to recover that debt.

We provide services in conjunction with payment processors which may include processors such as financial or merchant facility providers (such as Paypal, Stripe etc). When you delete your account with us, we delete your personal data retained by us, except to the extent we are prevented by law from deleting your personal information or data. However, to delete any payment or billing information, you will need to do so with your payment provider, as we only have minimal secure access to those records as needed to provide the services.

Marketing

We do not provide your Personal Information to any other person for marketing purposes. Except as specified in this Privacy Policy, we will not sell your personal information.

From time to time, we may use your Personal Information to provide you with information on any relevant industry developments, including sending you email alerts, offers for services, materials, promotions and competitions, campaigns to participate in and to communicate any other relevant information.  We do not, however, use Sensitive Information for this purpose.

If you no longer wish to receive these alerts, unsubscribe links are provided in every email that you receive.  If at any time you no do not wish to receive any additional material from us, contact our Privacy Officer and we will remove your details from our marketing database.

Anonymous Dealings 

You are not obliged to give us your Personal Information. If you would like to access any of our Services on an anonymous basis, please advise us in writing. If it is possible and lawful, we will take reasonable steps to comply with your request. However, if you choose not to provide us with some or all of your Personal Information, we may not be able to provide you with some part or all of our Services (or our assistance will be restricted at our discretion).

Disclosing Personal Information 

Disclosure to Third Parties

We may disclose your Personal Information to third parties in certain circumstances including:

  • if you agree to the disclosure;
  • when we use it for the purpose for which it was collected (e.g., to provide you with Services);
  • between our related entities;
  • your spouse or partner;
  • in circumstances where you would reasonably expect information of that kind to be passed to a third party;
  • our contracted software solutions providers; IT contractors and database designers and Internet service suppliers; Legal and other professional advisors; Insurance brokers, loss assessors and underwriters; 
  • where disclosure is required or permitted by law (including under the Privacy Act), by court order, or is required to investigate suspected fraud or other unlawful activity; or
  • if disclosure will prevent or lessen a serious or imminent threat to someone’s life or health.

External Sites

Please note we are not responsible for the practices or content of other services or sites that are operated by third parties but which are linked to our website. If we are linked to third party services or sites, it does not necessarily constitute sponsorship, endorsement or approval by the website of the content, policies or practices of those services or sites. If you leave our website via such a link, you should check the privacy policy of the third party site.

We may use third parties to manage the website and activities from time to time, including, but not limited to, promotions and statistical analysis. These parties may have access to and store the personal information of users of the website. Similarly, we may contract with third parties to handle requests for information submitted to us.

If you become a registered user of any of third party applications, you will be taken to consent to:

  • your personal data being transferred to and processed in countries where our hosting servers are located;
  • us using your personal information to check your identity, including to check your status (e.g. as a member of a defined user group) and for any merchant facility arrangement we have with bankers, their respective related bodies corporate, and their respective officers, employees and agents;
  • use of your personal information by us and our authorised personnel and service provider contractors; for example, to improve service we may provide your personal information as statistical data to others for research and analysis purposes; and as another example we may use Google Analytics and give you notice of its operation on the webpage titled “How Google uses data when you use our partners' sites or apps” (located at google.com/policies/privacy/partners/).
  • us disclosing your personal information in situations where we reasonably believe it is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering with our rights, either intentionally or unintentionally; and
  • us disclosing your personal information to law enforcement agencies and others if we in good faith believe we are legally obligated to do so.

Children under the age of 18

We do not knowingly collect or solicit personal information from anyone under the age of 18 (or the age of majority in your jurisdiction) or knowingly allow such persons to register. If you are under 18, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 is permitted to provide any personal information. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at info@sharepass.online 

Business Transfer

If the ownership changes of all or a substantial part of our business, or individual business units, your Persona Information (including your profile with the website) may be transferred to the new owner so the service or the transferred part of it can continue operations. In any such transfer of information, your personal information would remain subject to this Privacy Policy at the time of the transfer and then to the privacy policy of the new owner.

Considerations when you send Information to Us Electronically

If you send an email to us (including any emails addressed to us the information in your email (including any Personal Information) may be retained on our systems in accordance with applicable email retention policies and procedures.

While we do all we reasonably can to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including investing in security software, no data transfer over the Internet is 100% secure.

If you access another website from our website, you do so and provide personal information in accordance with the terms and conditions under which the provider of that website operates.

The open nature of the Internet is such that information exchanged via the internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including (without limitation) Personal Information, is sent through the Internet or other electronic means at your own risk.

While we are not in a position to give you advice on internet security, if you provide Personal Information to us electronically, there are some things you can do which may help maintain the privacy of your information, including:

  • always closing your browser when you have finished your session; and
  • never providing Personal Information when using a public computer.

You should contact us immediately if you believe:

  • someone has gained access to Personal Information you have provided to us;
  • we have breached our privacy obligations or your privacy rights in any way; or
  • you would like to discuss any issues about our privacy policy.

How we act to protect and retain your Personal Information

We endeavour to keep our information systems and files secured from unauthorised access.  Those who work with us are aware of the legal obligations in respect to confidentiality and the importance we place on protecting your privacy.

Our procedures to securely store Personal Information include electronic and physical security measures, staff training and use of password protection software.

We retain our files for at least seven years.  However, information filed in our electronic files may be retained indefinitely.

Personal Information may also be retained if we consider it necessary to do so or to comply with any applicable law or our insurance, governance obligations in our IT back-up records, for the collection of any monies owed and to resolve disputes.

How you can update or correct your Personal Information

You may request access to your Personal Information or correct any inaccurate or out of date information by contacting our Privacy Officer using the details below.  

For security purposes, before we provide you with personal information, we may ask you to provide evidence of your identity.

You may request the source of any information we collect from a third party.  We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld.

If there is a reason under the Privacy Act or other law for us not to provide you with information, we will give you a written notice of refusal setting out the reasons for the refusal except to the extent it would be unreasonable to do so and the mechanisms available to you to complain about the refusal.

If you provide us with your personal information and you later decided that you would no longer like to receive information from us, follow the "unsubscribe" directions at the end of any email or other communication you receive from us. You may withdraw consent by deleting your account at any time.

How to complain if you believe we have breached the Australian Privacy Principles (APP)

If you believe that we have dealt with your Personal Information in a way that is inconsistent with the APP, you should contact our Privacy Officer in the first instance using the details below.  

We will attempt to respond to your complaint within 30 days.

If we are unable to resolve your complaint you may contact the Office of the Australian Information Commissioner (contact details are below).

Important Notice to Non-Australian Residents

If you are located outside the location of servers, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to Australia. 

You may have additional rights under applicable data protection laws, including the EU General Data Protection Regulation (GDPR). For example, you may have the right to lodge a complaint with the data protection supervisory authority in your country. You may also have the right to request access to and rectification or erasure of your Personal Information or restriction of processing of your Personal Information, or to object to processing, as well as the right to data portability. 

We respect the privacy rights of all of our users. Upon request to info@sharepass.online we will provide you with confirmation as to whether we are processing your Personal Information, and have the data communicated to you within a reasonable time. You have the right to correct, amend or delete your Personal Information where it is inaccurate or has been processed in violation of this Privacy Policy. 

Please allow us a reasonable time to respond to your inquiries and requests. We are committed to complying with data protection laws to the extent they apply to us, and to assist our users in exercising their rights under applicable law.

Changes to this Privacy Policy

This is our current Privacy Policy. Our Privacy Policy will be updated periodically, with the updated version posted on our website www.sharepass.online

By visiting the Website, downloading or updating the Applications, and/or otherwise accessing and/or using the Service after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Contact Details

If you would like further information on our Privacy Policy or if you have any concerns over the protection of the information you have given to us or that we have collected from others, please contact our Privacy Officer at info@sharepass.online.

More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Australian Information Commissioner at:

Website: www.oaic.gov.au
Post: GPO Box 5218 Sydney NSW 2001
Email: enquiries@oaic.gov.au

In this Privacy Policy:

The meaning of any general language is not restricted by any accompanying example and the words ‘includes’, ‘including’, ‘such as’, ‘for example’ or similar words are not words of limitation.