Justification for Our Privacy Policy
This Privacy Policy applies to Personal Information we collect from users of our Sites, Apps, Wi-Fi hotspots, and other online services, as well the Personal Information we collect about individuals, including current and prospective clients, visitors to our sites, and others with whom we interact whether online, via phone, or offline in the course of providing our services.- 1 - Documentation of User Data
The ways in which we collect, process, and secure information vary depending on the nature of the Services we offer, the type of data, and legal and regulatory requirements. We and our third party service providers collect personal information about you from a variety of sources, including from you directly (e.g., when you fill out forms available on our websites to provide contact information or other personal information as part of a request for information, when you sign up for a newsletter, or when you register an account with us to access our Services), data we generate about you in the course of our relationship with you (e.g., data collected from cookies and other similar technologies as described below), and data we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law). The categories of personal data that we may collect directly from you include the following:- Personal details (e.g. name, date of birth);
- Contact details (e.g. phone number, email address, postal address or mobile number for yourself, your parents or guardians, and/or other emergency contacts);
- Account details (e.g. username and password);
- Transaction details (e.g. when you make purchases or respond to offers);
- Communications (e.g. when you participate in message boards or forums, participate in polls or surveys, or contact us with a question, comment or request);
- Records of our interactions with you; and
- Internal notes, including notes about your inquiry into our programs and services.
- Data that we generate about you as a result of your use of the Services (e.g. our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services).
- Personal details (e.g. name, date of birth);
- Contact details (e.g. phone number, email address, postal address or mobile number);
- Details about advertising preferences (e.g. products purchased or interaction with advertisements online);
- 2 - Your Data's Role in Our Operations
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:- internal record keeping;
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time.
- 3 - Data Sharing with Affiliates
Our website contains links to other websites. This privacy policy only applies to this website, so when you access another website from a link, you should read their own privacy policies.- 4 - Website Privacy and Security Policy
Sharing of personal information For the sole purpose of fulfilling Our contractual obligations towards You and Our business partners We may share personal information within Company Network. Company Network will process your personal information in accordance with this privacy policy and all privacy and communications legislation. We will not share with sell lease or otherwise distribute your personally identifiable Personal Information to any third party organisations outside of Company Network without first obtaining Your permission to do so. In particular, we will not release your Personal Information to any authorised direct marketing agents without first obtaining your prior consent Accordingly, you agree and acknowledge that:- (a) we may transfer personal information about You to any member or members of the Company Network for the purpose of fulfilling our contractual obligations with You; and
- (b) some countries where other facilities or companies or third party organisations are situated may have no data protection legislation or laws; and
- (c) in the event that we need to transfer your personal information to any member or members of the Company Network for the sole purpose of fulfilling our contractual obligations we will use reasonable endeavours to procure (but cannot guarantee) that such companies or third party organisations give binding contractual undertakings in order to ensure that Your rights with regards to any such processing and Your personal information will remain adequately protected.