1. We respect your privacy
1.1. Refni One Pty Ltd (ABN 45 617 679 713) (“Refni”) respects your right to privacy and is committed to safeguarding the privacy of its customers, application users and website visitors. Refni will adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and, to the extent applicable, the EU General Data Protection Regulation (“GDPR”). This policy sets out how we collect and treat your personal information. Please take a moment to review our privacy practices and contact us at firstname.lastname@example.org if you have any questions.
1.2. “Personal information” is information we hold which is identifiable as being about you.
2. Collection of personal information
2.1. Refni is a video-based, qualitative insights engine that helps creators and innovators (“Creators”) make more informed, inclusive and humanised decisions. You may be asked to provide personal information any time you are in contact with us. In particular, Refni will, from time to time, receive and store personal information you enter onto our website and/or application, provide to us directly or give to us in other forms. You are not required to provide any personal information we request but, if you choose not to, we may not be able to provide services to you or respond to your queries.
2.2. You may provide basic information such as your name, phone number, picture, address and email address to enable us to facilitate your conversations and other interactions with Creators, send information or provide updates. We will also collect the content of any conversation that you submit in response to a request from a Creator. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your contact or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
2.3. Additionally, we may also collect any other information you provide while interacting with us. Our systems may automatically process content and communications you and others provide to analyze context and what is in them for the purposes described in this Policy.
2.4. Where you provide us with unsolicited personal or sensitive information which we do not require to deliver products or services to you (for example, in a conversation with a Creator or on a phone call that is recorded), such information will be subject to our normal security arrangements for customer information. Where reasonable to do so, we will not hold unsolicited personal or sensitive information we do not require, however often we are unable to delete such information, particularly where it forms part of correspondence, phone records or other interactions that we do need to retain. Deletion in such circumstances is generally not reasonable or practicable.
3. How we collect your personal information
4. How we use of your personal information
4.1. Refni may use your personal information collected from you to make available to Creators the content of your conversation response and to provide you with information, updates and our services. We may also use your personal information to identify trends and to provide incentives, as well as to make you aware of new and additional products, services, conversations with Creators, surveys and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.
4.2. Refni may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.
4.3. If you withhold your personal information, it may not be possible for us to provide you with our services or for you to fully access our website or application.
4.4. Refni will use personal information only for the purposes that you consent to.
5. Disclosure of your personal information
5.1. When you agree to participate in a conversation you consent to us making your response to the conversation available to the Creator. We will disclose your personal information to Creators when you respond to a conversation posted by that Creator. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services or where you otherwise consent.
5.2. From time to time we may need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
5.3. We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Refni, www.refni.com, its Creators, its customers or third parties.
5.4. Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. These may include, but are not limited to the United States, Canada, the United Kingdom, Ireland, India and Japan.
5.5. We and our other group companies have offices and/or facilities in the United States, Canada, the United Kingdom, Ireland, India and Japan. Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following:
(a) the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission website;
(b) the use of binding corporate rules, a copy of which you can obtain from Refni’s Data Protection Officer.
5.6. The hosting facilities for our website are situated in the United States, Canada, the United Kingdom, Ireland, India and/or Japan. Transfers to each of these countries will be protected by appropriate safeguards. These include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission website; or the use of binding corporate rules, a copy of which you can obtain from Refni’s Data Protection Officer.
5.7. Our Suppliers and Contractors are situated in the United States, Canada, the United Kingdom, Ireland, India and/or Japan. Transfers to each of these countries will be protected by appropriate safeguards. These include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission website; or the use of binding corporate rules, a copy of which you can obtain from Refni’s Data Protection Officer.
5.8. You acknowledge that personal data that you submit for publication through our website, application or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5.9. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
6. Security of your personal information
6.1. Refni is committed to ensuring that the information you provide to us 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 information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
6.2. We will take reasonable steps to protect your personal information from unauthorised disclosure. However, please note that the transmission of personal information via the internet is outside of our control and there is a risk that information transmitted in this way could be intercepted by third parties.
6.3. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that they have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
7. General Data Protection Regulation (GDPR) for the European Union (EU)
7.1. Where applicable Refni will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
7.2. We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
7.3. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
7.4. We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.
7.5. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
7.6. We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
7.7. We do not collect or process any personal information from you that is considered “Sensitive Personal Information” under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtain your explicit consent, or it is being collected subject to and in accordance with the GDPR.
7.8. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.
8. Your rights under the GDPR
8.1. If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Refni complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
8.2. Except as otherwise provided in the GDPR, you have the following rights:
(a) to be informed how your personal information is being used;
(b) to access your personal information (we will provide you with a free copy of it);
(c) to correct your personal information if it is inaccurate or incomplete;
(d) to delete your personal information (also known as “the right to be forgotten”);
(e) to restrict processing of your personal information;
(f) to retain and reuse your personal information for your own purposes;
(g) to object to your personal information being used; and
(h) to object against automated decision making and profiling.
8.4. We may ask you to verify your identify before acting on any of your requests.
9. Access to your personal information
9.1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth) and, to the extent applicable, the GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at email@example.com.
9.2. We may decline to process requests that are frivolous or vexatious, that jeopardise the privacy of others, that are extremely impractical or for which access is not otherwise required under the Privacy Act or other applicable law.
10. Complaints about privacy
10.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to Refni One Customer Service, 35 Market Street, South Melbourne, Victoria, 3205, Australia. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
12. Website data and third party sites
12.1. When you come to our website www.refni.com or our application we may collect certain information such as browser type, operating system, website visited immediately before coming to our website, etc. This information is used in an aggregated manner to analyse how people use our website or application, such that we can improve our service.
12.4. Our website and application may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Refni is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
This policy is provided by Refni One Pty Ltd (ABN 45 617 679 713) and was last updated on 11 November 2018.