Zipline Cloud Pty Ltd trading as Pendula Solutions ACN 613 136 824 (referred to in this document as we, us or our) are committed to protecting the personal information we collect from you.
Subject to exceptions, the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) govern the handling of personal information in Australia. This document sets out how we will manage your personal information.
We provide intelligent, omni-channel communications solutions that are optimised to integrate with various software platforms. As such, we engage with personal information in two capacities. First, as a primary collector (or ‘data controller’ in privacy-speak), for instance if you are our customer or if you visit our website. Second, as a service provider to other organisations who are the primary collector (or ‘data processor’ in privacy-speak).
Our relationship with you is very different in those two circumstances. In the first, we have collected information from you to maintain your relationship with us. But in the second, we are given limited access (usually via an Application Programming Interface, or ‘API’) to information that sits in other platforms (like SalesForce) so that our customers can use our communications solutions to engage with you. We treat those situations differently.
Types of information collected
If you are our customer, we may collect and hold personal information about you, that is, information that can identify you, and is relevant to providing you with the services you are seeking. In particular, we may collect:
your name and contact details (including your email address and telephone number);
banking, credit card, or other payment information;
related information such as your company name and website information; and
If you are our customer’s customer, we may access or receive certain of your personal information as necessary to provide our communications services. For instance, we may be given your mobile telephone number in order to be able to send you an SMS and the contents of that SMS (e.g. appointment bookings).
We also receive access to the information you include in your communications with our customers (for instance, if you respond to an SMS sent by our platform on behalf of our customer).
Purpose of collection
The personal information that we collect and hold about you depends on your interaction with us.
If you are our customer, we will generally collect, use and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the purposes of:
providing services to you or someone else you know;
providing you with promotional material and information about other goods and that we, our related entities and other organisations that we have affiliations with, offer that may be of interest to you;
facilitating our internal business operations, including the fulfilment of any legal requirements;
analysing our services and customer needs with a view to developing new or improved services.
If you are our customer’s customer, we process your information for the purposes of providing our messaging services to our customer. Typically, this means we use your information for the purpose of sending you messages, analysing the contents of your messages to determine the most appropriate response, and delivering your messages to our customer.
Method of collection
If you are our customer, personal information will generally be collected directly from you through the use of any of our standard forms, over the internet, via email, through a telephone conversation with you, or in person. There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
If you are our customer’s customer, we receive your personal information through an API that connects to our customer’s customer relationship management system, or similar platform that holds your information. We do not notify you of this collection directly, because it is not practicable for us to do so. In the circumstances of our relationship with you, we rely on our customer to notify you that they may use services like ours and that personal information may be disclosed to us. We take reasonable steps to ensure they are aware of and comply with this obligation.
Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking.
If you are our customer’s customer, you separately control your privacy settings with our customers, through your direct relationship with them. If you do not provide your information to them, they may not be able to provide their services to you.
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Use and disclosure
If you are our customer, generally we only use or disclose personal information about you for the purposes for which it was collected (as set out above). We may disclose personal information about you to:
service providers, who assist us in operating our business, including
our related entities and other organisations with whom we have affiliations so that those organisations may provide you with information about services and various promotions; and
Google Analytics who assist us in analysing our services and customer needs with a view to developing new or improved services. Further information how Google Analytics collects and processes data is available at www.google.com/policies/privacy/partners
If you are our customer’s customer, we only use your personal information as necessary to perform our services for our customer. We do not separately process your personal information for our own purposes unless you are separately our customer.
We may run anonymised analytics on data that is transmitted through our services, but this does not identify you and is not personal information.
Disclosure of personal information overseas
We are not likely to disclose your personal information overseas, except as permitted by the Privacy Act, unless we otherwise advise you in writing.
We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from interference, misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
Access and correction
You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
Complaints and feedback
If you wish to make a complaint about a breach of the Privacy Act, the APPs or a privacy code that applies to us, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.
Street address: Level 1, 234 Crown Street Darlinghurst NSW 2010
For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.
If you wish to make a complaint about the collection, use or disclosure of your personal information, please contact our privacy officer, and we will work with you to resolve the issue.
If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at www.oaic.gov.au/privacy/privacy-complaints to obtain the relevant complaint forms, or contact the Information Commissioner’s office.
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