GROW IMPACT PRIVACY POLICY

 

1. Introduction

This website and derivatives using the same domain name (the “Website”) and our online applications (“Grow Impact Platform”) is created, managed and controlled by Grow Impact Pty Ltd (ABN 83 642 198 114) of 45 St Georges Terrace, Perth, Western Australia, 6000 (“Grow Impact”, “we”, “us” or “our”).

We are committed to ensuring your personal information is protected. We manage your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (“Privacy Act”).

By accessing and using our Website, the Grow Impact Platform (and any products or services made available to you on, or via, the Website or Grow Impact Platform) you agree to this Privacy Policy.

This Privacy Policy outlines how we collect, store, use and disclose your Personal Information, and how you may access your Personal Information (as defined in the Privacy Act) kept by us or how you may make a privacy complaint.

 

2. Grow Impact collects your personal information

Personal information is information or an opinion about you which identifies you, or which is reasonably capable of identifying you, whether or not the information is true or recorded in a material form.

We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver our Website, the Grow Impact Platform and our products and services to you, or as otherwise permitted by law.

The type of personal information that we collect and use depends on the type of dealings that you have with us and includes the following:

(a)     contact details (for example, full name, address, mobile and telephone numbers and email address);

(b)     business details (for example, business name, business address, work mobile and office telephone numbers and work email address);

(c)     information relating to your dealings, or enquiries you have made, with us;

(d)     payment and billing information;

(e)     information regarding your access and use of our website, including location information, your computer’s internet protocol (IP) address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on your website, dates and times of visits to our website and other usage statistics (see sections 12 and 13 below); and

(f)      other information that you provide to us or that we may collect in the course of our relationship with you.

We do not collect your Sensitive Information (as defined by the Privacy Act).

 

3. How Grow Impact collects personal information

We will collect personal information about you in a number of different ways. We may collect personal information directly from you or in the course of our dealings with you. For example, when you:

(a)     register to use the Grow Impact Platform and our products and services;

(b)     when you contact or correspond with us, including online, by email or via telephone;

(c)     post to the Grow Impact Community forum or on our blog;

(d)     contact the Grow Impact support team; and

(e)     visit our website.

You can always choose not to provide your personal information to Grow Impact, but it may mean that we are unable to deliver our Website, the Grow Impact Platform and our products and services to you.

 

4. Grow Impact may receive personal information from you About others

Through your use of the Website, the Grow Impact Platform or our products and services Grow Impact may also collect personal information from you about someone else. If you provide Grow Impact with personal information about someone else, you must ensure that you are authorised to disclose that personal information to Grow Impact and that, without Grow Impact taking any further steps required by the Privacy Act, Grow Impact may collect, use and disclose such personal information for the purposes described in this Privacy Policy.

This means that you must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Privacy Policy, including the fact that their personal information is being collected, the purposes for which that personal information is being collected, the intended recipients of that personal information, the individual’s right to obtain access to that information, Grow Impact’s identity, and how to contact Grow Impact.

Where requested to do so by Grow Impact, you must also assist Grow Impact with any requests by the individual to access or update the personal information you have collected from them and submitted and stored on or via, the Website or Grow Impact Platform.

 

5. Grow Impact collects, holds and uses your personal information for limited purposes

(a)     Grow Impact will only use your personal information for the purposes described in this Privacy Policy or with your express permission. For example, we may use your personal information for the following purposes: provide or deliver the Website, the Grow Impact Platform or our products and services

(b)     verify your identity;

(c)     charge and bill you for the use of the Grow Impact Platform or our products and services;

(d)     notify you of new or changed services offered in relation to the service;

(e)     carry out marketing or training relating to the service;

(f)      assist with the resolution of technical support issues or other issues relating to the service,

(g)     administer, manage and improve our Website, the Grow Impact Platform or our products and services (we continually strive to improve our Website, the Grow Impact Platform and our products and services offerings based on the information and feedback we receive from you);

(h)     improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);

(i)       administer a contest, promotion, survey or other site feature;

(j)       administer online interest-based advertising programs;

(k)     to improve our online advertising programs;

(l)       share with our Third Party Providers (see section 8 below);

(m)   comply with laws and regulations in applicable jurisdictions; and

(n)     communicate with you.

By using our Website, the Grow Impact Platform or our products and services, you consent to your personal information being collected, stored, shared, disclosed and used in accordance with this Privacy Policy.

It is your responsibility to keep your password to the service safe. You should notify us as soon as possible if you become aware of any misuse of your password, and immediately change your password within the Grow Impact Platform service or via the Forgotten Password or Change Password processes (depending on the version of Grow Impact used).

Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

 

6. Grow Impact can aggregate your non-personally identifiable data

By using the Website, the Grow Impact Platform or our products and services, you agree that Grow Impact can access, aggregate and use non-personally identifiable data that Grow Impact has collected from you. This data will in no way identify you or any other individual.

Grow Impact may use this aggregated non-personally identifiable data to:

(a)     assist us to better understand how our customers are using the service;

(b)     provide our customers with further information regarding the uses and benefits of the Website, the Grow Impact Platform or our products and services;

(c)     enhance small business productivity, including by creating useful business insights from that aggregated data and allowing you to benchmark your business’ performance against that aggregated data; and

(d)     otherwise to improve the Website, the Grow Impact Platform or our products and services.

 

7. Grow Impact Holds your Personal Information on Servers Located in Australia

All data, including personal and non-personal information, that is collected and stored on our Website and on the Grow Impact Platform (whether uploaded by you or by automated means), is transferred to Grow Impact’s servers as a function of transmission across the Internet. By using the Website, the Grow Impact Platform or our products and services, you consent to your personal information being transferred to our servers as set out in this Privacy Policy.

Currently our servers are located in Australia and hosted by Amazon Web Services. Your personal information will be routed through, and stored on, those servers as part of the service. Amazon Web Services complies with relevant aspects of security and is built to satisfy the requirements of the most security-sensitive organisations. For more on AWS Cloud Compliance please see AWS Cloud Compliance.

If the location of our servers’ changes in the future, we will update this policy. You should review our Privacy Policy regularly to keep informed of any updates.

By providing your personal information to Grow Impact, you consent to Grow Impact storing your personal information on servers hosted in Australia.

While your personal information will be stored on servers located in, Australia, it will remain within Grow Impact’s effective control at all times. The server host’s role is limited to providing a hosting and storage service to Grow Impact, and we have taken steps to ensure that our server hosts do not have access to your data and that we use the necessary level of protection to protect your personal information.

If you do not want your personal information to be stored on a server provided by AWS located in Australia, you should not provide Grow Impact with your personal information or use the Grow Impact Platform and our products and services.

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.

 

8. Disclosure to Third Party Providers

In order to provide or deliver our Website, Grow Impact Platform and our products and services to you we may disclose your personal information to:

(a)     our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers, external business advisors or other authorised external service providers who perform functions on our behalf (such as marketing and analysis organisations, financial and credit card institutions to process payments, hosting companies, web developers, internet service providers, customer service providers, customer support specialists, fulfilment companies, external business advisors (including auditors and lawyers), our insurer, and research and data analysis firms) (collectively, “Third Party Providers”); and

(b)     law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law.

Prior to the disclosure of personal information to Third Party Providers, we will take such steps as reasonable in the circumstances to ensure that the Third Party Providers treat your personal information securely and otherwise complies with the relevant Australian Privacy Principles in relation to the personal information.

 

9. Grow Impact Takes Steps to Protect your Personal Information

Grow Impact is committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your personal information is stored on secure servers that have SSL Certificates.

We will advise you at the first reasonable opportunity upon discovering, or being advised of, a security breach where your personal information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.

 

10. Grow Impact only Discloses your Personal Information in Limited Circumstances

Grow Impact will only disclose the personal information you have provided to us to entities outside the Grow Impact group of companies if it is necessary and appropriate to facilitate the purpose for which your personal information was collected pursuant to this policy, including the provision of the service. Grow Impact will not otherwise disclose your personal information to a third party unless you have provided your express consent.

If you are a researcher, this means that we may share your information and details of your activity with your institution, your funder, or other units of work you are associated with.

You should be aware that Grow Impact may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas, or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

The third parties who host our servers do not control and are not permitted to access or use your personal information except for the limited purpose of storing the information. This means that, for the purposes of Australian privacy legislation and Australian users of the service, Grow Impact does not currently “disclose” personal information to third parties.

 

11. You may Request Access to your Personal Information

It is your responsibility to ensure that the personal information you provide to us is accurate, complete and up-to-date. You may request access to the information we hold about you, or request that we update or correct any personal information we hold about you, by setting out your request in writing and sending it to us at privacy@growimpact.com.au

Grow Impact will process your request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know why. For example, it may be necessary for us to deny your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for us to process your request in the manner you have requested. In some circumstances, it may be necessary for us to seek to arrange access to your personal information through a mutually agreed intermediary.

We’ll only keep your personal information for as long as we require it for the purposes of providing you with the service. However, we may also be required to keep some of your personal information for longer specified periods of time.

 

12. Grow Impact Uses Cookies

In providing the service, Grow Impact utilises “cookies”. A cookie is a small text file that is stored on your computer for record-keeping purposes. A cookie does not identify you personally or contain any other information about you, but it does identify your computer.

We and some of our affiliates and third-party service providers may use a combination of “persistent cookies” (cookies that remain on your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when you close your browser) on the Website to, for example, track overall site usage, and track and report on your use and interaction with ad impressions and ad services.

You can set your browser to notify you when you receive a cookie so that you will have an opportunity to either accept or reject it in each instance. However, you should note that refusing cookies may have a negative impact on the functionality and usability of the Website.

We use analytics tools and other third-party technologies, such as Google Analytics and Double Click cookies, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and/or Services. These tools and technologies collect and analyse certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behaviour and usage information, feature use metrics and statistics, usage history, MAC Address, mobile unique device ID, and other similar information.

The third-party analytics companies who collect information on our Sites and/or Services and other online products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.

In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of Grow Impact Sites and/or Services and to otherwise collect and use data about your use of our Website, Grow Impact Platform and our products and services. For more information about this practice, please see the “Third Party Advertising Technologies” section below.

You may opt out of the Double Click cookie by visiting the Google advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics opt-out page.

Google has additional information available about their remarketing Privacy guidelines, policies and Restrictions.

We do not respond to or honour “Do Not Track” requests at this time.

 

13. Third Party Advertising Technologies

In addition to using cookies and related technologies as described above to inform, optimise, and serve adverts based on visitors’ past visits to your Website, we also may permit certain third party companies, including Google, to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on our Sites and/or Services (e.g., to allow them to tailor adverts on third party services). These companies may deliver adverts that might also place cookies and otherwise track user behaviour. These companies may use information about user behaviour in order to provide customised advertisements across various services and products. In the course of providing these services, products or placing advertisements, these third-party companies may place or recognise a unique cookie on your computer and may record information to these cookies based upon your activities on any of our Sites and/or Services and on third party websites across the internet. Each of these companies uses this cookie information according to their own privacy and security policies. If you wish to not have this information used for the purpose of serving you targeted adverts, you may opt-out as indicated in this Policy.

In particular, Grow Impact may make use of combinations of the following third-party products to target advertising and advertise online: LinkedIn advertising, Google Analytics Google Remarketing, Google Display Network Impression Reporting, integration with the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting. Visitors can opt-out of Google Analytics for Display Advertising and customise Google Display Network adverts through the follow settings page (https://www.google.com/settings/ads).

Grow Impact may also use data from first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the Double Click cookie) together to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to Grow Impact sites.

Using Google Analytics Demographics and Interest Reporting, Grow Impact may use data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics in order to better target our advertising.

 

14. You can Opt-out of any Email Communications

Grow Impact sends billing information, product information, service updates and service notifications to you via email. Our emails will contain clear and obvious instructions describing how you can choose to be removed from any mailing list not essential to the Grow Impact Platform and our products and services. Grow Impact will remove you at your written request.

You are responsible the for transfer of your data to third-party applications.

The Grow Impact Platform and our products and services may allow, customers and authorised users of the Grow Impact Platform and our products and services  to transfer data, including personal information, electronically to and from third-party applications. Grow Impact has no control over, and takes no responsibility for, the privacy practices or content of these applications. You are responsible for checking the privacy policy of any such applications so that you can be informed of how they will handle personal information.

 

15. Grow Impact has a Privacy Complaints Process

If you wish to complain about how we have handled your personal information, please provide us with full details of your complaint and any supporting documentation by e-mail at privacy@growimpact.com

We will endeavour to:

(a)     provide an initial response to your query or complaint within 10 business days, and

(b)     investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.

 

16. Your consent

By using our Website, the Grow Impact Platform or our products and services, you consent to our Privacy Policy.

Grow Impact reserves the right to change this Privacy Policy at any time, and any amended policy is effective upon posting to the Grow Impact website. Grow Impact will make every effort to communicate any significant changes to you via email or notification via the Grow Impact Platform.

Your continued use of the service will be deemed acceptance of any amended policy.

This Privacy Policy was last modified on 28 July 2021.

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