Privacy
policy
Introduction
We (Cradle Pay Pty Ltd ABN 91 626 294 237) take our privacy obligations seriously and
we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.
By providing personal information to us, you consent to our storage, maintenance, use and
disclosing of personal information in accordance with this privacy policy.
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We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988
(Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store,
secure and dispose of your personal information. Capitalised words in this Privacy Policy
have the same meaning as in the Terms of Use available on the Platform.
Types of personal information we collect
The personal information we collect may include the following:
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1. Registration information: this includes information that we collect when you
register to use our Platform by creating an Account. The information we collect
includes your name, mailing or street address, email address, social media
information, telephone number and other contact details, age and any other
information you directly give us at the registration stage.
2. Platform use information: When you use our Platform, for example for quotes or
for invoicing arrangements we collect information that enables the Platform to be
able to run. This includes details contained in a quote such as customer details,
milestone details, imagery, messages, payment amounts as well as information
regarding the invoicing arrangements such as transaction details and funding
instruments used to complete the transaction. This may also include any
information given during a dispute.
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3. Participant information: When you use the Platform to send quotes or send
requests for payment, or respond to any requests, we collect the details of each
party to facilitate the transaction. If you are a Customer, we will also collect your
details when a Contractor provides them to us.
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4. Surveys: information in connection with client surveys, questionnaires and
promotions;
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5. Other information we collect related to your use of the Platform: your device
identity and type, I.P. address, geo-location information, page view statistics,
advertising data and standard web log information and any other information
provided by you to us via our Platform or our online presence, or otherwise
required by us or provided by you.
We do not intend to collect any sensitive information about you.
How we collect personal information
We may collect personal information either directly from you, or from third parties, including
where you:
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a) register or sign up to the Platform;
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b) use the Platform to create quotes or invoices, or respond to them;
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c) where you are a party to a transaction;
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d) contact us through our website;
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e) submit any of our online sign up forms;
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f) communicate with us via email, telephone, SMS, social applications (such as
LinkedIn, Facebook or Twitter) or otherwise;
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g) interact with our website, social applications, services, content and advertising;
and
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h) invest in our business or enquire as to a potential purchase in our business.
Where we collect your personal information from a third party, we will take reasonable steps
to ensure that you are made aware of the information provided to us by the third party.
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We may also collect personal information from you when you use or access our website or
our social media pages. This may be done through use of web analytics tools, 'cookies'; or
other similar tracking technologies that allow us to track and analyse your website usage.
Cookies are small files that store information on your computer, mobile phone or other device
and enable and allow the creator of the cookie to identify when you visit different websites. If
you do not wish information to be stored as a cookie, you can disable cookies in your web
browser.
Use of your personal information.
We collect and use personal information for the following purposes:
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to operate the Platform and provide services or information to you including to:
o enable us to send quotes you create and manage them;
o send or request payment of an invoice;
o enable you to communicate with other users;
o confirm your identity;
o communicate with you about your Account, or any transaction;
for record keeping and administrative purposes;
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to provide information about you to our contractors, employees, consultants,
agents or other third parties for the purpose of providing goods or services to you;
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to improve and optimise our service offering and customer experience;
to comply with our legal obligations, resolve disputes or enforce our agreements
with third parties;
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to send you marketing and promotional messages and other information that may
be of interest to you and for the purpose of direct marketing (in accordance with
the Spam Act). In this regard, we may use email, SMS, social media or mail to
send you direct marketing communications. You can opt out of receiving
marketing materials from us by using the opt-out facility provided (e.g. an
unsubscribe link);
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to send you administrative messages, reminders, notices, updates, security
alerts, and other information requested by you; and
to consider an application of employment from you.
Disclosure of your personal information
We may disclose your personal information to cloud-providers, contractors and other third
parties located inside or outside of Australia. If we disclose personal information outside of
Australia, we will take reasonable steps to ensure that any overseas recipient deals with such
personal information in adherence with the Australian Privacy Principles.
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We may also disclose your personal information to those third parties involved in your use of
the Platform. This includes:
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the other User you are transacting with;
any payment agent of ours;
any service providers.
Storage & security
We store your personal information on web servers in Australia. Please be aware that we
may use third-party cloud providers that provide hosting, data storage and other services.
We take reasonable steps to ensure your personal information is secure and protected from
misuse or unauthorised access. Our information technology systems are password protected,
and we use a range of administrative and technical measure to protect these systems.
However, we cannot guarantee the security of your personal information.
We will retain your Personal Information for the period necessary to fulfil the purposes
outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Links
Our website may contain links to other websites. Those links are provided for convenience
and may not remain current or be maintained. We are not responsible for the privacy
practices of those linked websites and we suggest you review the privacy policies of those
websites before using them.
Requesting access or correcting your personal information
Subject to the Privacy Act, you have a right to access and correct any personal information
about you that we may hold. If you wish to request access to the personal information we hold
about you, please contact us using the contact details set out below including your name and
contact details. We may need to verify your identity before providing you with your personal
information. In some cases, we may be unable to provide you with access to all your personal
information and where this occurs, we will explain why. We will deal with all requests for
access to personal information within a reasonable timeframe.
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If you think that any personal information we hold about you is inaccurate, please contact us
using the contact details set out below and we will take reasonable steps to ensure that it is
corrected.
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If we receive a request from you to access or correct Personal Information we will respond to
you within a reasonable time after receiving your request and in the manner requested by
you, if it is reasonable and practicable for us to do so. We may charge a reasonable fee for
giving access to the information.
If we can't collect your personal information
If you do not provide us with the personal information described above, some or all of the
following may happen:
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we may not be able to provide the Platform to you, either to the same standard or at
all;
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we may not be able to provide you with information about the Platform that you may
want; or
we may be unable to tailor the content of our Platform to your preferences and your
experience of our websites may not be as enjoyable or useful.
Notifiable data breach
In the event that there is a data breach and we are required to comply with the notification of
eligible data breaches provisions in Part IIIC of the Privacy Act or any other subsequent
sections or legislation which supersede this Part IIIC, we will follow our relevant notifiable
data breach procedures in compliance with the Privacy Act and relevant laws.
Updates
This Privacy Policy is subject to occasional revision and we reserve the right, at our sole
discretion, to modify or replace any part of this Privacy Policy. It is your responsibility to check
this Privacy Policy periodically for changes. Continued use of our website or services shall
indicate your acknowledgement of that it is your responsibility to review the Privacy Policy
periodically and become aware of any modifications. We may amend this Privacy Policy from
time to time. Not all changes to our Privacy Policy will require your consent, for example
where office security procedures are changed. We will notify you of any change to our
information handling policy that requires your consent before being implemented.
Enquiries, request & complaints
Enquiries regarding this Privacy Policy or the personal information we may hold on you,
should be addressed with the Privacy Officer, whose contact details are below.
If you think your personal information, held by us, may have been compromised in any way or
you have any other Privacy related complaints or issues, you should also raise the matter
with the Privacy Officer.
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We will ensure your claims are investigated and a formal response will be provided to you,
within a reasonable time, considering the circumstances of your claims. If any corrective
action is determined to be required, as a result of that investigation, we will take all
reasonable steps to rectify the situation and advise you of such, again within a reasonable
time considering the circumstances.
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If we do not resolve your enquiry, concern or complaint to your satisfaction or you require
further information in relation to any privacy matters, please contact the Office of the
Australian Information Commission, whose contact details are below.
Office of the Australian information Commission
Telephone 1300 363 992
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Email enquiries@oaic.gov.au
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Office Address Level 3, 175 Pitt Street, Sydney NSW 2000
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Postal Address GPO Box 5218, Sydney NSW 2001
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Website www.oaic.gov.au
Contacting us
Entity Cradle Pay Pty Ltd
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Telephone 1300 339 609
Email enquiries@cradlepay.com
Office Address 9 -17 Raglan street South Melbourne 3205
Postal Address As above
Website www.cradlepay.com