Privacy Policy

Privacy Policy –  360 Digital Care PTY LTD

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means 360 Digital Care PTY LTD  (ACN 649 594 847). We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information. 

By providing Personal Information to us, you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on the Website. We encourage you to check the Website periodically to ensure that you are aware of our current Privacy Policy.

Personal Information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.

  1. Definitions
    1. In this Privacy Policy, the following capitalised terms have the following meanings:

Non-personal Information means information which does not relate to a person and/or cannot be used to identify a person. 

Personal Information means any information which can be used to identify an individual, and described in detail in clause 2.  

Privacy Act means the Privacy Act 1998 (Cth).

Services means any services offered on the Website. 

Spam Act means the Spam Act 2003 (Cth). 

Uploaded Content means any content whatsoever which you upload to the Website, including but not limited to any descriptions, reviews, usage data, feedback, comments, chats, media.

User means any person using or registering on the Website whatsoever.

Website means the website and any Services offered under the name “Avanavo”.

  1. What Personal Information do we collect?
    1. We may collect Personal Information about you when you use the Website, register on the Website or interact with us in any way. 
    2. Information you provide to us: We collect all information which Users voluntarily provide to us through using the Website or interacting with us. This includes information provided:
      1. during registration;
      2. during correspondence, enquiries, emails to our helpdesk, over phone calls, or as part of customer surveys; or
      3. uploaded onto the Website in any way.

The Personal Information we may collect includes without limitation:

  1. basic information such as your first and last name; 
  2. contact information including email address and phone number; 
  3. demographic information such as postal code, age, and gender; 
  4. information related to Services purchased by you;
  5. other relevant information in relation to your Services needs; 
  6. geographic location; 
  7. login credentials for third-party websites; 
  8. other information obtained by your use of the Website; and 
  9. any other information that enables users to be personally identified. 
  1. Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Website (Automatic Data). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Website, details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries, or information about how you came to the Website. We collect Automatic Data based on your consent which was granted to us by you when you registered as a User and accepted this Privacy Policy.
  2. Information we obtain from others: We may also collect or receive Personal Information from third party sources, such as other Users, suppliers, social media or other third-party integrations.
  1. Why do we collect, use and disclose Personal Information?
    1. We may collect, hold, use and disclose your Personal Information for the following purposes:
      1. to enable you to access and use our Website, purchase Services and interact with Users;
      2. to operate, protect, improve and optimise our Website, business and our Users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
      3. to send you Service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
      4. to send you marketing and promotional messages and other information that may be of interest to you, including information sent on behalf of our business partners that we think you may find interesting;
      5. to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
      6. to comply with our legal obligations, resolve any disputes that we may have with any of our Users, and enforce our agreements with third parties.
    2. We may also disclose your Personal Information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the Services that you receive.
    3. The information we collect is not distributed, sold or leased to third parties for commercial purposes, except to provide Services you have requested or for other purposes when we have your permission or when we are obliged to do so.
  2. Do we use your Personal Information for direct marketing?
    1. We may send you direct marketing communications and information about the Services offered on our Website. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us through the contact us feature below, or by using the opt-out facilities provided (e.g. an unsubscribe link).
  3. To whom do we disclose your Personal Information?
    1. We may disclose Personal Information for the purposes described in this Privacy Policy to:
      1. our employees and related bodies corporate;
      2. third-party suppliers and service providers (including providers for the operation of our Website and/or our business or in connection with providing our Services to you);
      3. professional advisers, dealers and agents;
      4. payment systems operators (eg merchants receiving card payments); 
      5. our existing or potential agents, business partners or partners;
      6. our sponsors or promoters of any competition that we conduct via our Services;
      7. anyone to whom our assets or businesses (or any part of them) are transferred;
      8. specific third-parties authorised by you to receive information held by us; and/or
      9. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
  4. Using our websites and cookies
    1. We may collect Personal Information about you when you use and access our Website. While we do not use browsing information to identify you personally, we may record certain information about your use of our Website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer. 
    2. We may also use ‘cookies’ or other similar tracking technologies on our Website that help us track your Website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our Website may not work as intended for you if you do so.
    3. We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy. 
  5. Security
    1. We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information. 
  6. Retention
    1. We may retain your Personal Information as long as you are registered to the Website as a User. You may close your account by contacting us. However, we may retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
  7. Exclusions
    1. Links: Our Website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
    2. Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Website or through any other means, or information posted by you to any public areas of the Website. 
  8. Accessing or correcting your Personal Information
    1. You can access the Personal Information we hold about you by contacting us using the contact us feature below. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.
    2. If you think that any Personal Information we hold about you is inaccurate, please contact us using the contact us feature below and we will take reasonable steps to ensure that it is corrected.
    3. We will consider and respond to all requests in accordance with all applicable laws.
  9. Making a complaint
    1. If you think we have breached the Privacy Act or any other relevant privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us using the contact us feature below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take. 
  10. Contact Us
    1. For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us using the details set out below:
    2. [Insert contact us function or otherwise include email address]

Effective: [2021-05-01]