SEEDIT PTY LTD – PRIVACY POLICY
Seedit
Pty Ltd (ABN 50 657 909 638) (we, us or our), understands that protecting your personal information is
important. This Privacy Policy sets out our commitment to protecting the
privacy of personal information provided to us, or otherwise collected by us
when providing our website and Gooie platform (Services) or when otherwise interacting
with you.
This Privacy Policy takes
into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In addition to
the Australian laws, individuals located in the European Union or European Economic
Area (EU) may also have rights under the General Data Protection
Regulation 2016/679 and individuals located in the United Kingdom (UK)
may have rights under the General Data Protection Regulation (EU) 2016/679) (UK
GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR).
Appendix 1 outlines the details of the additional rights of individuals located
in the EU and UK as well as information on how we process the personal
information of individuals located in the EU and UK.
The
information we collect
Personal information: is information
or an opinion, whether true or not and whether recorded in a material form or
not, about an individual who is identified or reasonably identifiable.
The types of personal
information we may collect about you include:
·
Identity
Data including first name, middle name,
last name, date of birth, business name.
·
Contact Data including email address, business email address and address.
·
Financial
Data including bank account and payment
card details.
· Purchasing Data including
your order history for any businesses that are on the Gooie
Platform.
·
Background Verification
Data including your photographic
identification or other details requested as part of our verification process
to comply with our due diligence obligations, anti-money laundering laws and
related ongoing monitoring commitments.
·
Transaction
Data including details about payments
to you from us and from you to us and other details of products and services
you have purchased from us or we have purchased from
you.
·
Technical
and Usage Data including internet protocol (IP)
address, your login data, your browser session and geo-location data, device
and network information, statistics on page views and sessions, acquisition
sources, search queries and/or browsing behaviour, information about your
access and use of our website, including through the use of Internet cookies,
your communications with our website, the type of browser you are using, the
type of operating system you are using and the domain name of your Internet
service provider.
·
Profile Data including your username and password for the Gooie
platform, profile picture, support requests you have made, content you post,
send receive and share through our platform, information you have shared with
our social media platforms, your interests, preferences, feedback and survey
responses.
·
Marketing and
Communications Data including your preferences
in receiving marketing from us and our third parties and your communication
preferences.
Sensitive
information is a sub-set of
personal information that is given a higher level of protection. Sensitive
information means information relating to your racial or ethnic origin,
political opinions, religion, trade union or other professional associations or
memberships, philosophical beliefs, sexual orientation or practices, criminal
records, health information or biometric information. Unless otherwise
permitted by law, we will not collect sensitive information about you without
first obtaining your consent.
How
we collect personal information
We collect
personal information in a variety of ways, including:
Directly: We collect personal
information which you directly provide to us, including when you register for
an account on the Gooie platform, make
recommendations on the Gooie platform, through the
‘contact us’ form on our website or when you request our assistance via email, or
over the telephone.
Indirectly: We may collect personal
information which you indirectly provide to us while interacting with us, such
as when you use our website, in emails, over the telephone and in your online
enquiries.
From third
parties: We collect personal information from third parties, such as details of
your use of our website from our analytics and cookie providers and marketing
providers. See the “Cookies” section below for more detail on the use of
cookies.
From publicly available sources: We collect personal data
from publicly available resources such as the Australian Securities and
Investment Commission (ASIC).
Why
we collect, hold, use and disclose personal information
We have set out below, in a table format, a description of the purposes
for which we plan to collect, hold, use and disclose your personal information.
|
Purpose of use / disclosure |
Type of Personal Information |
|
To enable you to access and
use the Gooie platform, including to provide you
with a login. |
·
Identity Data ·
Contact Data |
|
To assess whether to take
you on as a new client, including to perform anti-money laundering,
anti-terrorism, sanction screening, fraud and other background checks on you. |
·
Identity Data ·
Contact Data ·
Background Verification Data |
|
To be able to pay you your referral
commission where you are an endorser on our Gooie
Platform |
·
Identity Data ·
Contact Data ·
Financial Data |
|
To provide our Services to you,
including to allow you to list your products on our Gooie
Platform or make recommendations of products on our Gooie
Platform. |
·
Identity Data ·
Contact Data ·
Purchasing Data |
|
To contact and communicate
with you about our Services including in response to any support requests you
lodge with us or other enquiries you make with us. |
·
Identity Data ·
Contact Data ·
Profile Data |
|
To contact and communicate
with you about any enquiries you make with us via our website. |
·
Identity Data ·
Contact Data |
|
For internal record keeping,
administrative, invoicing and billing purposes. |
·
Identity Data ·
Contact Data ·
Financial Data ·
Transaction Data ·
Purchasing Data |
|
For analytics including
profiling on our website, market research and business development, including
to operate and improve our Services, associated applications and associated
social media platforms. |
·
Profile Data ·
Technical and Usage Data ·
Purchasing Data |
|
For advertising and
marketing, including to send you promotional information about our events and
experiences and information that we consider may be of interest to you. |
·
Identity Data ·
Contact Data ·
Technical and Usage Data ·
Profile Data ·
Marketing and Communications Data |
|
To run promotions, competitions
and/or offer additional benefits to you. |
·
Identity Data ·
Contact Data ·
Profile Data ·
Marketing and Communications Data ·
Purchasing Data |
|
To comply with our legal
obligations or if otherwise required or authorised by law. |
· Any
relevant Personal Information |
Our
disclosures of personal information to third parties
We may disclose personal information to:
our
employees, contractors and/or related entities;
merchants
who list their products on our Gooie platform;
IT
service providers, data storage, web-hosting and
server providers such as AWS;
marketing
or advertising providers such as Shopify, Meta;
professional
advisors, bankers, auditors, our insurers and insurance brokers;
payment
systems operators such as PayPal, Airwallex;
our
existing or potential agents or business partners;
sponsors
or promoters of any promotions or competition we run;
anyone
to whom our business or assets (or any part of them) are, or may (in good
faith) be, transferred;
courts,
tribunals and regulatory authorities, in the event you fail to pay for goods or
services we have provided to you;
courts,
tribunals, regulatory authorities and law enforcement officers, as required or
authorised by law, in connection with any actual or prospective legal
proceedings, or in order to establish, exercise or defend our legal rights;
third
parties to collect and process data, such as Google Analytics (To find out how
Google uses data when you use third party websites or applications, please see
www.google.com/policies/privacy/partners/ or any other URL Google may use from
time to time), Meta Pixel or other relevant analytics businesses; and
any
other third parties as required or permitted by law, such as where we receive a
subpoena.
Google
Analytics: We
may have enabled Google Analytics Advertising Features including Remarketing
Features, Advertising Reporting Features, Demographics and Interest Reports,
Store Visits, Google Display Network Impression reporting. We and third-party
vendors may use first-party cookies (such as the Google Analytics cookie) or
other first-party identifiers, and third-party cookies (such as Google
advertising cookies) or other third-party identifiers together.
You
can opt-out of Google Analytics Advertising Features including using a Google
Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the
Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all
cookies are deleted from your browser you can install their plugin here. To opt out
of interest-based ads on mobile devices, please follow these instructions for
your mobile device: On android open the Google Settings app on your device and
select “ads” to control the settings. On iOS devices with iOS 6 and above use
Apple’s advertising identifier. To learn more about limiting ad tracking using
this identifier, visit the settings menu on your device.
Overseas
disclosure
While we store
personal information in Australia, where we disclose your personal information
to the third parties listed above, these third parties may store, transfer or
access personal information outside of Australia. We will only disclose your
personal information overseas in accordance with the Australian Privacy
Principles.
Your
rights and controlling your personal information
Your choice: Please read this Privacy Policy
carefully. If you provide personal information to us, you understand we will
collect, hold, use and disclose your personal information in accordance with
this Privacy Policy. You do not have to provide personal information to us,
however, if you do not, it may affect our ability to provide our Services to
you and your use of our Services.
Information from third parties: If we
receive personal information about you from a third party, we will protect it
as set out in this Privacy Policy. If you are a third party providing personal
information about somebody else, you represent and warrant that you have such
person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to
processing for direct marketing/unsubscribe from our email database or opt-out
of communications (including marketing communications), please contact us using
the details below or opt-out using the opt-out facilities provided in the
communication.
Access: You may request access to the
personal information that we hold about you. An administrative fee may be
payable for the provision of such information. Please note, in some situations,
we may be legally permitted to withhold access to your personal information. If
we cannot provide access to your information, we will advise you as soon as reasonably
possible and provide you with the reasons for our refusal and any mechanism
available to complain about the refusal. If we can provide access to your
information in another form that still meets your needs, then we will take
reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date,
incomplete, irrelevant or misleading, please contact us using the details
below. We will take reasonable steps to promptly correct any information found
to be inaccurate, out of date, incomplete, irrelevant or misleading. Please
note, in some situations, we may be legally permitted to not correct your
personal information. If we cannot correct your information, we will advise you
as soon as reasonably possible and provide you with the reasons for our refusal
and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint,
please contact us using the details below and provide us with full details of
the complaint. We will promptly investigate your complaint and respond to you,
in writing, setting out the outcome of our investigation and the steps we will
take in response to your complaint. If you are not satisfied with our response,
you also have the right to contact the Office of the Australian Information
Commissioner.
Storage
and security
We are committed
to ensuring that the personal information we collect is secure. In order to
prevent unauthorised access or disclosure, we have put in place suitable
physical, electronic and managerial procedures, to safeguard and secure personal
information and protect it from misuse, interference, loss and unauthorised access,
modification and disclosure.
While we are
committed to security, we cannot guarantee the security of any information that
is transmitted to or by us over the Internet. The transmission and exchange of
information is carried out at your own risk.
Cookies
We may use
cookies on our website from time to time. Cookies are text files placed in your
computer's browser to store your preferences. Cookies, by themselves, do not
tell us your email address or other personally identifiable information. However,
they recognise
you when you return to our online website and allow third parties, such as
Google and Facebook, to cause our advertisements to appear on your social media
and online media feeds as part of our retargeting campaigns. If
and when you choose to provide our online website with personal
information, this information may be linked to the data stored in the cookie.
You can block
cookies by activating the setting on your browser that allows you to refuse the
setting of all or some cookies. However, if you use your browser settings to
block all cookies (including essential cookies) you may not be able to access
all or parts of our website.
For more
information about the cookies we use, please see https://goo.ie/landing/cookie.
Links
to other websites
Our website may
contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and
privacy of any personal information which you provide whilst visiting those websites.
Those websites are not governed by this Privacy Policy.
Personal
information from social network accounts
If you connect
your account with us to a social network account, such as Google or Facebook, we
will collect your personal information from the social network. We will do this
in accordance with the privacy settings you have chosen on that social network.
The personal
information that we may receive includes your name, ID, user
name, handle, profile picture, gender, age, language, list of friends or
follows and any other personal information you choose to share.
We use the
personal information we receive from the social network to create a profile for
you on our Gooie platform.
If you agree, we
may also use your personal information to give you updates on the social
network which might interest you. We will not post to your social network
without your permission.
Where we have
accessed your personal information through your Facebook account, you have the
right to request the deletion of personal information that we have been
provided by Facebook. To submit a request for the deletion of personal
information we acquired from Facebook, please send us an email at the address
at the end of this Privacy Policy and specify in your request which personal
information you would like deleted. If we deny your request for the deletion of
personal information, we will explain why.
Use
of Google API Services (this section applies to personal information accessed
through Google API Services)
We use Google’s
Application Programming Interface (API) Service to access your email and
name information in order to create accounts and personalise communication with
you.
Our use of
information received from Google APIs will adhere to the Google
API Services User Data Policy, including the
Limited Use requirements (set out in the Google API Services User Data Policy).
We limit our use
of the personal information that we collect to providing or improving our
Services. We do not use the personal information for any other purposes.
We only transfer
the personal information to others if it is necessary to provide or improve our
Services or as necessary to comply with applicable law or as part of a merger,
acquisition or sale of assets where we notify you of this.
We do not use or
transfer the personal information for serving ads, including retargeting,
personalised or interest based advertising.
These
restrictions apply to the raw data we obtain from the restricted scopes and
data that is aggregated, anonymised or derived from them.
We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.
We
collect your precise or approximate location for the following purposes:
to enable
you to make recommendations for businesses in your locality;
for security and safety;
to prevent and detect fraud; and
as permitted by law.
We
collect this information when you use our Services. If you do not want us to
use your location for the purposes above, you should turn off the location
services in your mobile phone settings. If you do not provide geolocation data
to us, we may not be able to provide our Services to you.
Amendments
We may, at any
time and at our discretion, vary this Privacy Policy by publishing the amended
Privacy Policy on our website. We recommend you check our website regularly to
ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact
us at:
Seedit Pty Ltd (ABN 50657909638)
Email: support@goo.ie
Last update: 1 February 2023
APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS
LOCATED IN THE EU OR UK
Under the GDPR
individuals located in the EU and the UK have extra rights which apply to their
personal information. Personal information under the GDPR is often referred to
as personal data and is defined as information relating to an identified or
identifiable natural person (individual). This Appendix 1 sets out the
additional rights we give to individuals located in the EU and UK, as well as
information on how we process the personal information of individuals located
in the EU and UK. Please read the Privacy Policy above and this Appendix
carefully and contact us at the details at the end of the Privacy Policy if you
have any questions.
What
personal information is relevant?
This Appendix
applies to the personal information set out in the Privacy Policy above. This
includes any Sensitive Information also listed in the Privacy Policy above
which is known as ‘special categories of data’ under the GDPR.
Purposes
and legal bases for processing
We collect and
process personal information about you only where we have legal bases for doing
so under applicable laws. We have set out below, in a table format, a
description of all the ways we plan to use your personal information, and which
of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate. Note that we may process your
personal information for more than one lawful ground depending on the specific
purpose for which we are using your data. Please reach out to us if you need
further details about the specific legal ground, we are relying on to process
your personal information where more than one ground has been set out in the
table below.
|
Purpose of use / disclosure |
Type of Data |
Legal Basis for processing |
|
To enable you to access and use our Gooie platform, including to provide you with a login. |
·
Identity Data ·
Contact Data |
·
Performance of a contract with you |
|
To assess whether to take you on as a new
client, including to perform anti-money laundering, anti-terrorism, sanction
screening, fraud and other background checks on you. |
·
Identity Data ·
Contact Data ·
Background Verification Data |
·
Performance of a contract with you ·
To comply with a legal obligation ·
Public interest ·
Legitimate interests: ensuring we do
not deal with proceeds of criminal activities or assist in any other unlawful
or fraudulent activities for example terrorism |
|
To be able to pay you your referral commission where
you are an endorser on our Gooie Platform |
·
Identity Data ·
Contact Data ·
Background Verification Data |
·
Performance of a contract with you |
|
To provide our Services to you, including to
allow you to list your products on our Gooie
Platform or make recommendations of products on our Gooie
Platform. |
·
Identity Data ·
Contact Data ·
Purchasing Data |
·
Performance of a contract with you |
|
To contact and communicate with you about
our Services including in response to any support requests you lodge with us
or other enquiries you make with us. |
·
Identity Data ·
Contact Data ·
Profile Data |
·
Performance of a contract with you |
|
To contact and communicate with you about
any enquiries you make with us via our website. |
·
Identity Data ·
Contact Data |
·
Legitimate interests: to ensure we
provide the best client experience we can offer by answering all of your questions. |
|
For internal record keeping, administrative,
invoicing and billing purposes. |
·
Identity Data ·
Contact Data ·
Financial Data ·
Transaction Data |
·
Performance of a contract with you ·
To comply with a legal obligation ·
Legitimate interests: to recover
debts due to us and ensure we can notify you about changes to our terms of
business and any other administrative points. |
|
For analytics including
profiling on our website, market research and business development, including
to operate and improve our Services, associated applications and associated
social media platforms, |
·
Profile Data ·
Technical and Usage Data ·
Purchasing Data |
·
Legitimate interests: to keep our
website updated and relevant, to develop our business, improve our Services
and to inform our marketing strategy |
|
For advertising and marketing, including to
send you promotional information about our events and experiences and
information that we consider may be of interest to you. |
·
Identity Data ·
Contact Data ·
Technical and Usage Data ·
Profile Data ·
Marketing and Communications Data |
·
Legitimate interests: to develop our
Services and grow our business |
|
To run promotions, competitions and/or offer
additional benefits to you. |
·
Identity Data ·
Contact Data ·
Profile Data ·
Marketing and Communications Data ·
Purchasing Data |
·
Legitimate interests: to facilitate
engagement with our business and grow our business |
|
To comply with our legal obligations or if
otherwise required or authorised by law. |
·
Any relevant Personal Information |
·
To comply with a legal obligation |
If you have
consented to our use of data about you for a specific purpose, you have the
right to change your mind at any time, but this will not affect any processing
that has already taken place. Where we are using your data because we or a
third party have a legitimate interest to do so, you have the right to object
to that use though, in some cases, this may mean no longer using our
services. Further information about your rights is available below.
Data
Transfers
The countries to
which we send data for the purposes listed above may be less comprehensive that
is what is offered in the country in which you initially provided the
information. Where we transfer your personal information outside of the country
where you are based, we will perform those transfers using appropriate
safeguards in accordance with the requirements of applicable data protection
laws and we will protect the transferred personal information in accordance
with this Privacy Policy and Appendix 1. This includes:
only
transferring your personal information to countries that have been deemed by
applicable data protection laws to provide an adequate level of protection for
personal information; or
including
standard contractual clauses in our agreements with third parties that are
overseas.
Data retention
We will only
retain your personal information for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any
legal, regulatory, tax, accounting or reporting requirements. We may retain
your personal information for a longer period in the event of a complaint or if
we reasonably believe there is a prospect of litigation in respect to our
relationship with you.
To determine the
appropriate retention period for personal information, we consider the amount,
nature and sensitivity of the personal information, the potential risk of harm
from unauthorised use or disclosure of your personal information, the purposes
for which we process your personal information and whether we can achieve those
purposes through other means, and the applicable legal, regulatory, tax,
accounting or other requirements.
Extra
rights for EU and UK individuals
You may request
details of the personal information that we hold about you and how we are
process it (commonly known as a “data subject request”). You may also have a
right in accordance with applicable data protection law to have your personal information
rectified or deleted, to restrict our processing of that information, to object
to decisions being made based on automated processing where the decision will
produce a legal effect or a similarly significant effect on you, to stop
unauthorised transfers of your personal information to a third party and, in
some circumstances, to have personal information relating to you transferred to
you or another organisation.
If you are not
happy with how we are processing your personal information, you have the right
to make a complaint at any time to the relevant Data Protection Authority based
on where you live. We would, however, appreciate the chance to deal with your
concerns before you approach the Data Protection Authority, so please contact
us in the first instance using the details set out below.
For any questions or notices, please
contact us at: support@goo.ie