Frasil - Privacy Policy

Frasil Group Pty Ltd and its affiliates operating under the Frasil name in other jurisdictions (together referred to as Frasil, we, our, us), are committed to protecting your privacy.

This privacy policy (Privacy Policy) sets out how we handle your personal information. In particular, this Privacy Policy sets out how we will handle any personal information that is disclosed, collected or otherwise handled in connection with the Frasil website (www.frasil.com) and all associated features, content and software applications (the Frasil Platform).

This Privacy Policy may change from time to time and it is therefore important that you review it regularly. Any change to this Privacy Policy will become effective when we publish the revised Privacy Policy on the Frasil Platform.

What personal information do we collect?

Personal information means information or opinion about an 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).

We may collect and use different kinds of information in the course of providing the services which we have grouped together as follows:

  • Contact information: includes your name, age, phone number, email address and your physical address;
  • Transaction information: includes details about payments from you and other details of products and services you have purchased from us;
  • Profile information: includes user generated information made available by social network services such as names, comments, posts, images or preferences, feedback and survey responses;
  • Sensitive information: includes information or an opinion, that is also personal information about health or a disability (at any time) of an individual. It also includes racial or ethnic origin, religious and philosophical beliefs, political or sexual orientation information;
  • Technical information: includes username and passwords, internet protocol (IP) address, your login data, browser type, time zone setting and location, third party access tokens and other technology on the devices you use to access the Frasil Platform;
  • Usage information: includes information about how you use the Frasil Platform, the types of content you interact with, the frequency and duration of time that you use the Frasil Platform’s products and services;
  • Content information: this includes the content of communications, people you are connected to and how you interact with them (such as people you communicate with or groups that you select to join), interactions between offerings including your preferences and choices;
  • Marketing information: includes your preferences in receiving marketing communications from us; and
  • any other personal information that you provide to us either directly or indirectly when using the Frasil Platform.

We do not hold or collect any payment information such as credit card details and billing addresses.

How do we collect your personal information?

We will collect personal information directly from you wherever it is reasonable and practical to do so.  We may collect personal information from you via:

  • your use and access of the Frasil Platform, including during your registration as a user;
  • your response to any surveys or marketing materials we send out;
  • information and recommendations uploaded to the Frasil Platform by yourself or by other users; and
  • interactions between yourself, other users of the Frasil Platform, and our staff.

We may also collect your personal information from third parties including:

  • third parties who provide services to Frasil that help us provide our services;
  • through other third parties using the Frasil Platform that provide information about you;
  • other third parties who provide services via the Frasil Platform; and
  • via public or private sources or when you connect with a social network service when using and accessing the Frasil Platform.

Why do we collect your personal information?

Frasil provides accessibility tools and applications, or access to accessibility tools and applications, to promote communication and engagement for persons living with disabilities using the Frasil Platform to connect to devices and the internet. To achieve this we collect your personal information for a variety of reasons including in the most common circumstances listed below:

  • to assess the performance of the Frasil Platform and to improve the services we provide;
  • to deliver targeted content based on user profiling and location;
  • to record your likes and preferences, for better navigation and service functionality;
  • to process and respond to a complaint or request you may make;
  • to contact you in relation to our services, particularly if we believe there are any products or services or any information we believe you might be interested in; or
  • for the provision of services or the administration of our business (including fulfilling and exercising our obligations and rights, exercising or defending legal claims and managing the relationship with you).

The legal basis for collecting and using personal information will depend on the specific circumstances in which it is collected. However we will collect personal information from you where:

  • you have given consent for Frasil’s use of the personal information for one or more purposes;
  • it is necessary for the performance of a contract to which you are party;
  • it is necessary for the legitimate interests pursued by Frasil and those interests are balanced against your rights to information privacy (e.g. to communicate useful content updates); or
  • we have legal obligations that we need to comply with, and are allowed to use your personal information in order to comply with such legal obligations.

Who may we disclose your personal information to?

We may disclose your personal information to various third parties. These third parties may include:

  • technology partners in connection with services that these third parties perform for us;
  • our lawyers, accountants and professional advisors;
  • other third party service providers, such as third party branding service providers;
  • to Frasil related companies that are either directly owned or controlled by Frasil;
  • to law enforcement authorities where we are required to do so by law or pursuant to a legal process, or when we believe disclosure is reasonably necessary or appropriate to prevent harm in connection to a suspected illegal activity; or
  • to any entity in the event that we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee uses the personal information you have provided to us in a manner that is consistent with this Privacy Policy.

We may also disclose your personal information outside of Australia and to other countries in which we do business from time to time, which may not provide the same level of protection for your personal information as Australia. In these situations Frasil will not be accountable for the actions of those recipients and you may have limited or no rights under the Australian privacy regime. Such disclosures include those to:

  • to Microsoft Azure (Azure) primarily located in the United States. However Azure has locations throughout the world. For more information about how Azure handles personal information please see here: https://privacy.microsoft.com/en-ca/privacystatement.
  • to Oracle Corporation (Oracle) primarily located in the United States. However Oracle has locations throughout the world. For more information about how service provider uses personal information please see here: https://www.oracle.com/legal/privacy/privacy-policy.html.
  • to Stripe, Inc (Stripe) primarily located in the United States. However Stripe has locations throughout the world. For more information about how service provider uses personal information please see here: https://stripe.com/au/privacy.
  • to Paypal Holdings Inc (PayPal) primarily located in the United States. However PayPal has locations throughout the world. For more information about how service provider uses personal information please see here: https://www.paypal.com/au/webapps/mpp/ua/privacy-full
  • to Frasil related entities for the purpose of providing the services in Australia, Canada, India, New Zealand and the United Kingdom.

Personal information collected within the European Union may be transferred to and processed by third parties located in a country outside of the European Union. In such instances Frasil shall ensure that the transfer of such personal information is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place.

What if we can’t collect your personal information?

If you do not provide us with the personal information we need, some or all of the following may occur:

  • you may not be able to use the Frasil Platform; and
  • we may not be able to provide you with targeted content and relevant information.

Direct Marketing

We may provide you with electronic marketing messages from time to time.  You may opt out of receiving electronic messages from us at any time by contacting our Privacy Officer via the contact details at the bottom of this Privacy Policy or by using the opt out mechanism included in our electronic marketing messages.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed. In addition we limit access to your personal data to employees, agents, contractors and other third parties who have a business need for access. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Access and Correction of Personal Information

We take reasonable steps to ensure that the personal information we handle is accurate, complete and up-to-date. If you become aware of any errors in your personal information or, if you change your personal information, please let us know.

You can request access to any personal information we hold about you at any time.  From time to time, we may need to reject your request to access personal information we hold about you, if we believe it to be necessary and to the extent allowed by law. To request access to any personal information that we may hold about you, please contact our Privacy Officer using the contact details at the bottom of this Privacy Policy.  Depending on your request and where permitted by law, we may charge a small fee for complying with your request.

You may request us to amend any personal information we hold about you which you believe to be inaccurate, incomplete or out of date. To request an amendment to any personal information that we hold about you, please contact our Privacy Officer using the contact details at the bottom of this Privacy Policy. If we do not agree to amend your personal information, you may request that we make a note of your requested correction with the information we hold about you.

If we are unable to, or if we are unwilling to provide you with access to any of your personal information, or to correct any of your personal information, we will provide you with our reasons.

You may also contact our Privacy Officer if you wish to obtain further information regarding our privacy practices and the way we handle your personal information.

Other Rights

Subject to certain limitations and restrictions (e.g. depending on circumstances such as where you reside) you may have the right to exercise additional rights in relation to your personal information. These may include the right to:

  • request erasure of your personal information
  • object to processing of your personal information
  • request restriction of processing of your personal information
  • transfer your personal information (i.e. the right to data portability)
  • not be subject to automatic decision making
  • withdraw consent

If you wish to exercise or obtain details of any of the rights set out above, please contact our Privacy Officer via the contact details at the bottom of this Privacy Policy. The Privacy Officer may require further information in order to assess the applicability of the right to the relevant circumstances.

Information Retention

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods for taking legal action.

Additional Services and Links to Other Sites

From time to time, we may provide links or mechanics to interface with other Frasil Platforms for your information or convenience or offer additional services through separate websites linked to this Frasil Platform. These websites operate independently from our Frasil Platform and may be subject to alternative terms of use, including terms concerning use of your personal information. We have not reviewed these third party sites and do not control and are not responsible for any of these websites, their content or their privacy policies. If you decide to access or interact with any of the third party sites listed on our Frasil Platform, you do so at your own risk.

Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with our Privacy Officer using the contact details set out at the bottom of this Privacy Policy. Our Privacy Officer will confirm receipt of your complaint.  If our Privacy Officer believes an investigation is necessary, we will open an investigation into your complaint. Our Privacy Officer may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, our Privacy Officer will contact you with the result of that complaint as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may be able to may contact the local privacy and data protection authorities. For reference, we set out below the identity of the relevant authorities:

  • Australia: the Office of the Australian Information Commissioner, www.oaic.gov.au
  • Canada: Office of the Privacy Commissioner of Canada, www.priv.gc.ca
  • United States of America: Federal Trade Commission, www.ftc.gov
  • New Zealand: the Office of the Privacy Commissioner, www.privacy.co.nz
  • United Kingdom: the Information Commissioner’s Office, www.ico.org.uk

Cookies

The Frasil Platform may use ‘cookies’ from time to time. Cookies could be used to collect personal information. A cookie is a small file that is stored on your device by a website. Cookies contain information which is readable by the website that issued the cookie to you and is commonly used to remember your details and preferences when you return to that website. Your web browser can be configured to reject cookies.  If you set up your web browser to reject cookies certain functions of our Frasil Platform may become unavailable to you.

Contact us

If you have any questions about this Privacy Policy, our privacy practices or if you would like to request access to or correction of any personal information we may hold about you, please contact our Privacy Officer:

Email: privacy@frasil.com

Phone: 02 9993 3850

Address: Level 12, 111 Elizabeth Street, Sydney, NSW 2000

Policy Version:

This Privacy Policy v1.0 was last updated on 12 November 2019