This privacy policy (“Privacy Policy”) together with our Website Terms and End User Licence Agreement and any other documents referred to therein, sets out the basis on which any personal data we collect from you within the European Union, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.floodgateapp.com/privacy/ (“Site”) you are accepting and consenting to the practices described in this Privacy Policy.
For the purpose of the Data Protection Act 1998 or any subsequent amendment or replacement or supplementary legislation (the “Act”), the data controller is Floodgate Pty Limited of Suite 8, 33 Heatherdale Road PO BOX 1046 Ringwood VIC 3134, Australia.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site, apps, subscribe to our services or newsletter, search for a product, place an order on our Site participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey and when you report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
Information we collect about you. With regard to each of your visits to our Site we may automatically collect the following information:
· technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
· information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
COOKIES
We use cookies on our Site to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve the Site. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the Site.
We use persistent cookies and session cookies on our Site. We use persistent cookies to save your login information for future logins to the Site. We use session cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and then close your browser.
Below explains the cookies we use and why we use each of them.
COOKIE NAME
Registration ASP>NET_Sessionid
Floodgate: SessionRef
COOKIE PURPOSE
When you sign in, we generate cookies that let us know whether you are signed in or not. Our servers use these cookies to work out which account you are signed in with.
You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use the whole of the Site or all functionality of the services.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
USES MADE OF THE INFORMATION
We use information held about you in the following ways.
Information you give to us. We will use this information:
· to carry out our obligations arising from any contracts entered into between you and us;
· to provide you with the information, products and services that you request from us;
· to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
· to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this by ticking the relevant box situated on the form on which we collect your data;
· to notify you about changes to our service;
· to ensure that content from our Site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
· to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to improve our Site to ensure that content is presented in the most effective manner for you and your computer;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our Site safe and secure;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
· to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
Information we share with third parties. We may share your information with selected third parties including:
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
· Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 250 women aged over 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men living in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
· Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
· Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
Information we disclose to third parties. We may disclose your personal data to third parties:
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
· If Floodgate Pty Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms or End User Licence Agreement and/or any other agreements; or to protect our rights, property, safety, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR PERSONAL DATA
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. Such staff or subcontractors maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the EEA.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your personal data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country provides an adequate level of protection) or where the recipient is bound by standard contractual clauses according to conditions provided by the European Commission (“EU Model Clauses”).
Our Site is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site from outside the EEA. This means that where you chose to post your data on our Site, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.
PROTECTION OF INFORMATION
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your data transmitted to our Site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
LINKS TO OTHER WEBSITES
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
YOUR RIGHTS
You have the right under the Act, free of charge, to request:
· Access to your personal data.
· Rectification or deletion of your personal data.
· A restriction on the processing of your personal data.
· Object to the processing of your personal data.
· A transfer of your personal data (data portability).
You can make a request in relation to any of the above rights by writing to us at the contact address given at the end of this Privacy Policy. We will respond to such queries within 30 days and deal with requests we receive from you, in accordance with the provisions of the Act.
CONSENT
You have the right to withdraw your consent to us processing your personal data, at any time, by writing to us at the contact address given at the end of this Privacy Policy.
Where we process your personal data for marketing purposes, we will inform you and obtain your opt in consent (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes. If you change your mind about being contacted in the future, please click on the opt out options and we will remove you from our mailing lists.
We send push notifications from time to time in order to update you about any service updates, events and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.
DATA RETENTION
We retain personal data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the Site to you, your account with us remains open or any period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using the Site for the purposes set out below.
After you have closed your account, or ceased using the Site for a period of at least 60 days, we usually delete personal data, however we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Website Terms and End User Licence Agreement, or fulfil your request to “unsubscribe” from further messages from us.
We will retain de-personalised information after your account has been closed.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the Site. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
COMPLAINTS
If you have any complaints about our use of your personal data please contact us as set out at the end of this Privacy Policy or contact our supervisory authority in Australia:
Office of the Victorian Information Commissioner, Privacy and Data Protection, PO Box 24274, MELBOURNE VIC 3001, Australia.
AGE OF USERS
This Site is not intended for and shall not be used by anyone under the age of 16.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. This Privacy Policy was last updated on 06/03/2018 and replaces any other Privacy Policy previously applicable from this date.
CONTACT
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:
Floodgate Pty Limited of Suite 8, 33 Heatherdale Road PO BOX 1046 Ringwood VIC 3134, Australia; or
By email: info@floodgateapp.com