Marketplace Manager - Privacy Policy

INTRODUCTION
This privacy policy (“Privacy Policy”) sets out how Swift Image Pty Ltd ACN 613 105 481 trading as MerchantSpring and its related bodies corporate (“we”, ”our”, ”us”) collects, stores, uses, protects, shares and discloses your personal information. It applies to our platform under the name “MerchantSpring” and its related services, websites, applications and tools (together the “Platform”). By visiting or using the Platform you agree to the collection, storage, usage and disclosure of your personal information by us in the manner described in this Privacy Policy.

Capitalised words in this Privacy Policy have the same meaning as in the Terms and Conditions available on the Platform.

TYPES OF PERSONAL INFORMATION WE COLLECT
As part of delivering our Services we may collect personal information about you as defined under the Privacy Act 1998 (“Privacy Act”). We will only collect personal information where it is reasonably necessary for the performance of our functions or activities. The personal information we collect may include the following:

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, telephone number and other contact details and any other information you directly give us at the registration stage.
User information: this includes information that you have provided to us when using the Platform and information we collect via API from any third party marketplace accounts that users connect to the Platform. The information we collect includes customer level data (such as addresses of customers), order level data (such as order numbers) and any other additional information you provide to us directly or indirectly through your use of the Platform and any connected marketplace account. We use such information to assist in providing the Services to you and will not use this information for any other purpose (such as marketing).
Profile information: this includes any information you choose to store on the Platform that will assist us in delivering the Services to you and includes information regarding any subscriptions.
Financial information: this includes information such as payment card details and bank account details. We use this information to send to our third party payment gateways.
Platform use information: When you use our Platform, for example when you contact us we collect information that enables the Platform to be able to run.
Surveys: information in connection with client surveys, questionnaires and promotions;
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.

HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information either directly from you, or from third parties, including where:

you register or sign up to the Platform (or when you login through social media);
you or a third party use the Platform to enter in user content or if you or a third party connect a marketplace account or service to the Platform and information is extracted through the API from your or that third party’s marketplace account (please see below);
you use the Platform generally;
you subscribe to any of our newsletters;
you contact us through our Platform;
you submit any of our online sign up forms;
you communicate with us via email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise;
you interact with our Platform, social applications, services, content and advertising; and
you 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.

User content or connection of marketplace accounts

As noted above, users of the Platform are able to input user content or connect a marketplace account to the Platform. Where this occurs we may extract data via API from that user’s marketplace account which may include customer level data and order level data (such as addresses and order numbers). If you are providing us information about others you must comply with the obligations set out under the Terms and Conditions. Where a user provides us this information about you we ensure that our agreements in place with those users include a warranty that we are entitled to use such data, you have consented to the collection, use, storage and transmission of such data and that any information provided is done in compliance with applicable laws. If you wish to withdraw such consent, please contact us and we will forward such request to the user. Third parties we may receive from include third parties that use our services, or provide technical, payment and delivery services to us and analytics providers or affiliate networks, and social media platforms.

Social media and cookies

We may also collect personal information from you when you use or access our Services 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 Services 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:

to operate the Platform and provide services or information to you including to:
assist in streaming and personalising information for you;
enable us to process your personal data;
to manage our relationship with you, including information about similar products or terms and conditions or send you an email reminder that a task you have performed on our Platform remains uncompleted such an incomplete form;
enable you to communicate with us regarding your use of the Platform;
confirm your identity;
to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing the Services to you;
communicate with you about your Account, or any transaction;
to be de-identified for the purposes of generating statistical data and improving the Platform;
for record keeping and administrative purposes;
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;
to administer and protect our Services;
to enable you to take part in a competition;
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 2003 (Cth)). 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);
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 our employees and volunteers, service providers who assist us to provide the Services to you such as information technology service 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.

We may also disclose your personal information to third parties to whom you expressly ask us to send the personal information to or to third parties where permitted under the Privacy Act. This also includes:

your authorised representatives;
government and regulatory authorities and other similar organisations, as required or authorised by law; and
such entities that we propose to merge with or be acquired by.
We may also disclose your personal information to third parties through the use of the Services where you have consented to such use.

We may also aggregate and/or make anonymous your personal information including sensitive information to make it available for the purposes of generating statistical data for the conducting of research and improving the Platform.

STORAGE & SECURITY
We 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 Services 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.

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.

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:

we may not be able to provide the Platform to you, either to the same standard or at all;
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 Services 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 Platform 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, REQUESTS & 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.

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.

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

Email [email protected]

Office Address Level 3, 175 Pitt Street, Sydney NSW 2000

Postal Address GPO Box 5218, Sydney NSW 2001

Website www.oaic.gov.au


Contacting us

Entity Swift Image Pty Ltd ACN 613 105 481 trading as Merchant Spring

Telephone 03 9013 7190

Email [email protected]

Office Address 9 Palmerston Cres, South Melbourne 3205 Victoria, Australia

Postal Address 9 Palmerston Cres, South Melbourne 3205 Victoria, Australia

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