Become Secure | Privacy Policy

Become Secure Privacy Policy

This Privacy Policy was last updated on 1 March 2024.

Definitions
1. In this Privacy Policy (Policy):
  1. Company Platform means the Become Secure APP or other platforms and websites of or managed by us and used by us to provide the Services, and server software used to provide the Services, as well as any other cloud based platform and includes any computer hardware on which the Become Secure APP or other platform, database, system or server software managed by us is installed.
  2. User, you means you as an individual, who is either an individual or the company or other legal entity on behalf of which you have been granted access to the Become Secure APP. Where you are accepting this Policy on behalf of a company or other legal entity on behalf of which you are accessing the Become Secure APP, you represent that you are authorised by that company or other legal entity to accept this Policy on its behalf.
  3. Personal Information means information about an identifiable natural person.
  4. Privacy Officer means the Privacy Officer, with contact details provided at clause 22.1.
  5. Services means any services that we provide through the Become Secure APP or other services offered by us from time to time either through the Become Secure APP or other Company Platform, as described on the Become Secure APP or other Company Platform.
  6. Become Secure APP means the Company Platform known as the ‘Become Secure’ App, managed by us to provide the Services.
  7. Become Secure, us, we, our means Become Secure Pty Ltd ACN 673 635 071 and all Related Body Corporates (across any jurisdiction).
Introduction
1. We are NOT subject to the Australian Privacy Principles (APPs), however, notwithstanding this have prepared this Policy to set out how we collect, handle and use Personal Information.
2. We reserve the right to update this Policy at any time without notice.
3. In certain circumstances we may also be subject to the EU General Data Protection Regulation (Regulation 2016/679) as it applies to residents in the European Economic Area (refer to clause 18.)
4. This Policy sets out how we collect, handle and use information that identifies you, for example: your name, email and address.
5. We care about your privacy and have put measures in place to protect you and the information you have entrusted to us.
6. We may update this Policy from time to time. While we will not provide notice of the changes to you and you can view the latest version of this Policy on the Become Secure APP at any time.
7. In this Policy we set out:
  1. the types of information that we may collect; and
  2. how that information will be used, handled, stored, and disclosed.
Application
1. This Policy applies to Personal Information that we may collect about you in the manner outlined in this Policy. To the extent permitted by law, or as otherwise set out in the Policy, this Policy does not apply to any information that may be collected by a third party and how that third party may use, handle, store or disclose your Personal Information.
Information we collect about you
1. We may collect, use, store and transfer Personal Information about you, which information is generally grouped into one of the following types of data:
  1. (Contact Information): being your first name, last name, gender, title, address, email address, telephone number, relationship status, profile picture, date of birth and username collected through the Become Secure APP or collected and input directly by you;
  2. (Financial Data): Your bank account details, credit card details or other payment information (to the extent required by law or by any payment processor);
  3. (Transaction Data): details about payments to and from you, and other details of the Products and Services you have purchased from us;
  4. (Usage Data): details of Services we have provided to you;
  5. (Technical Data): information regarding the IP addresses used to connect your computer or mobile phone to the internet, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system and platform or type of device;
  6. (Profile Data): your username or password from the Become Secure APP or other Company Platforms;
  7. (Marketing and Communications Data): information about how you use the Become Secure APP and our Services, being information regarding your preferencing in receiving marketing from us and your communication preferences;
  8. (Third-Party Data): subject to clause 9.2, information we may receive from third-parties such as business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers and search information providers, third party applications that plug into the Services;
  9. (Preferences Data): details regarding your interests, preferences, feedback and reviews; information, communication or opinions about any of our Services and transactions;
  10. (Social Media Activity): information regarding your interaction on social media activity, including “likes”, comments posted, any feedback, photos posted or uploaded and other information pertaining to your social media, including LinkedIn, Facebook, and Twitter, which concern, or relate, to Become Secure; and
  11. (Digital Data): Digital media and content such as video, footage and audio.
Collection of ‘sensitive information’
1. We will not request any sensitive information from you as defined under section 6(1) of the Privacy Act 1988 (Cth), unless:
  1. you are adequately informed before giving consent;
  2. you give consent voluntarily;
  3. the consent is current and specific;
  4. you have the capacity to understand and communicate their consent; or
  5. as required or authorised by or under an Australian law or a court/tribunal order.
How do we collect information from you
1. As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your Personal Information directly from you.
2. When you engage in certain activities, such as placing an order through the Become Secure APP, signing up to any promotional offer displayed on one of our Company Platforms or sending an inquiry or feedback to us, we may ask you to provide certain information. It is completely optional for you to engage in these activities.
3. We may use different methods to collect data from you and about you, including:
  1. (direct interactions) – you may give us your identity, contact, such as your name, sex, age, date of birth, address, email address, phone number, bio, photographs, voice recordings or when you communicate with us by email or through social media financial, profile and proof of identity data by creating an account with us, completing online forms or corresponding with us.
  2. (interactions you have with other sources) – subject to clause 9.2, we may receive identity, contact, financial, transaction, usage, marketing and communications data from third-parties such as business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers and third party applications that plug into the Services;
  3. (automated technologies or interactions) – we may collect information automatically when you download and access our Become Secure APP and Services, for example your IP address and device type or details of what you looked at and used in the Become Secure APP, what links you clicked on. This information is useful for us to improve the value of our Services to you. We may use the following technologies to collect technical and third-party data:
    1. “cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, please see: https://allaboutcookies.org;
    2. "log files” track actions occurring on the Become Secure APP, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and
    3. “web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Become Secure APP and Services.
How do we use your personal information?
1. We may use your personal data to:
  1. provide the Service to you;
  2. communicate with you;
  3. to register you as a new user or create an account with us;
  4. to provide technical or other support to you;
  5. to enhance, administer and manager the Become Secure APP and Services and develop new ones to administer and protect our business and the Become Secure APP;
  6. to deliver relevant Become Secure APP content and measure or understand the effectiveness of the Become Secure APP and to ensure the proper function of the Become Secure APP and online software;
  7. to protect you;
  8. to market to you including a newsletter and SMS messaging (if we choose to) and make suggestions and recommendations to you about goods, services or promotions that may be of interest;
  9. to analyse, aggregate and report;
  10. to improve the Services or businesses that we undertake;
  11. to maintain a record in the event of any Service or warranty request;
  12. to manage our relationship with you which may include, notifying you about changes to our terms or this Policy, asking you to leave a review or take a survey, engaging with you in relation to any support request or communication that you may submit;
  13. to facilitate internal training, ensure the effective delivery of Services and to resolve disputes or problems, whether initiated by us or you; and
  14. to improve our Services and business activities we undertake,

(the Primary Purposes).

Where we collect Personal Information, we will process the information only for the Primary Purpose, and:
1. where we have legitimate interests to process the personal data and they are not overridden by your rights;
2. in accordance with a legal obligation; and
3. where we have your consent.
Whether giving it is compulsory or voluntary
1. Become Secure will ensure that where possible, any Personal Information requested from you can be provided voluntarily or when requested, anonymously. In that event, you do not have to provide us with the personal data we request, but this may mean that you cannot use some parts of our Become Secure APP, the Company Platforms or the Services.
Data Retention
1. We will retain your Personal Information for as long as is necessary for a lawful purpose connected to our relationship with you or for the Primary Purposes.
2. If it is determined that we should not have possession of Personal Information under a relevant law, we will destroy the Personal Information or ensure that the Personal Information is de-identified.
3. We will only collect Personal Information from a third party where it is reasonably necessary for, or directly related to Become Secure’s functions or activities as outlined in clause 7 of this Policy.
Online Information and Google Analytics
1. Our Company Platforms may offer links to other websites. Those websites may also collect your Personal Information (including information generated through the use of cookies) when you visit them. We are not responsible for how such third parties collect, use or disclosure your Personal Information, so it is important to familiarise yourself with their privacy policies before providing them with your Personal Information.
2. In relation to Cookies and IP addresses, we disclose the following:
  1. if you use our website, we may utilise "cookies" which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer;
  2. we may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally;
  3. however, in some cases, cookies may enable us to aggregate certain information with other Personal Information we collect and hold about you. Become Secure extends the same privacy protection to your Personal Information, whether gathered via cookies or from other sources, as detailed in this Policy. As such, we do not aggregate non-personal information with any Personal Information unless we first notify you and obtain your consent;
  4. you can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our Company Platform or take advantage of the improved web site experience that cookies offer.
3. We use persistent cookies to enable basic web traffic analysis using Google Analytics which, for example, shows us which areas of our Company Platform are popular against those that are not visited often. This allows us to prioritise our enhancements to our Company Platforms and increase the productivity of our Company Platforms.
4. We undertake and use Google Analytics on our Company Platform. This feature does not use any Personal Information. We do not facilitate the merging of your Personal Information with any non-personal information unless we notify you and you opt-in to that merger. Click here for more information about how Google collects and uses data.
5. As a visitor to our Company Platform, you can opt out of your data being used Google Analytics by visiting Google Analytics’ site here for currently available opt-outs for the web.
Do Not Track Settings
1. Please note that we do not alter our Become Secure APP data collection and use practices when we see a ‘Do Not Track’ signal from your browser.
Storing your Information
1. To offer a consistent service to you we may store and manage data electronically or in paper form. Where data is stored electronically, it is done so by a third-party cloud service provider that may store your Personal Information (or a backup of your Personal Information) in a data centre or an online cloud service, as determined by the third-party provider from time to time.
2. The data that we collect from you may be transferred to and be stored to these servers or subject to clause 15, processed by staff operating in other jurisdictions or who work for us.
3. We will take all steps reasonably necessary to ensure that your information is secured from misuse, interference, loss, unauthorised access, unauthorised modification, or unauthorised disclosure. Any information will be handled in accordance with this Policy and applicable privacy laws. Despite using all steps reasonably necessary, the transmission of information through the internet is not completely secure.
4. Submission of any information to us is an acknowledgement that you agree to such use, storage, and disclosure as outlined in this Policy.
How we disclose your Information
1. There may be times when we need to share your Personal Information with third parties.
2. If we receive Personal Information from any third party, we will take reasonable steps to ensure that before we collect the information:
  1. we are satisfied that you would reasonably expect us to obtain the Personal Information;
  2. you have authorised the collection of that information; and
  3. that the information is accurate.
3. We may share your information with:
  1. any and all of our affiliates;
  2. third parties including business partners, suppliers and subcontractors;
  3. where we are required to disclose your information in order to comply with any legal obligation, to enforce any agreements; or to protect the rights, property, or safety of us and our customers, or others. This includes, where relevant, exchanging information with organisations for the purposes of fraud protection and credit risk reduction;
  4. an actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and
  5. other third-parties where we have your consent, including your implied consent given where disclosure is required for the performance of a contract with you.
When will we disclose personal information
1. Personal Information will only be used or disclosed for purposes related to the Primary Purposes for which it was collected and is relevant to you (as outlined in clause 7.1.) We will obtain consent from you where appropriate and necessary. Exceptions to this include where:
  1. the use or disclosure is required to lessen or prevent a serious and imminent threat to an individual’s life, health or safety, or to public health and safety;
  2. we suspects fraud or unlawful activity;
  3. the use or disclosure is necessary to assist a law enforcement agency in its law enforcement functions; or
  4. the use or disclosure is required or authorised by or under law.
International Data Transfers
1. By submitting your Personal Information to us, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information or Personal Data (as applicable) outside of Australia.
2. We may collect and store Personal Information globally from each jurisdiction we operate in and from each legal entity that is owned or operated by us in different international jurisdictions and may transfer, process and store your Personal Information outside of Australia, to wherever we or our third-party service providers operate for the Primary Purposes. We will take reasonable steps to ensure that any third-party service providers engaged outside of Australia to process and store your Personal Information, do so in accordance with this Policy and any applicable law.
3. If you do not agree to the disclosure of your personal information or Personal Data (as applicable) outside Australia by us, you should (after being informed of the cross border disclosure) tell us that you do not consent. To do this, either elect not to submit the Personal Information to us after being reasonably informed in a collection notification or please contact us via the details set out in clause 22.
Accessing and Correcting your Information
1. You may request access to Personal Information that we hold about you at any time by contacting our Privacy Officer (using the details set out in clause 22 of this Policy.) We will respond to any such request for access to Personal Information within a reasonable time and will provide you access to the Personal Information that we hold relating to you unless we are authorised not to do so by law.
2. Where permitted by law, we may charge you a reasonable fee for processing your request to access your Personal Information and should we decline you access to your Personal Information, a written explanation will be provided setting out the legal reasoning for doing so. For example, but not limited to, if the information doesn’t exist, cannot be located, the information may involve an unwarranted breach of someone else’s privacy, or releasing it may pose a serious threat to someone’s safety.
3. If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant, or misleading, please notify our Privacy Officer (using the details set out in clause 22 of this Policy.) We will take reasonable steps in the circumstances to ensure, having regard to the lawful purpose that it was collected, to ensure that the information is accurate, up to date, complete and not misleading.
4. If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided.
Complaints
1. If you believe we have not fulfilled our obligations under any relevant law or have not complied with the terms of this Policy or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer, using the contact details set out in this Policy.
2. We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
3. In Australia, if after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Australian Information Commissioner (AIC). The contact details of the AIC are listed on their website: www.oaic.gov.au
European Union
1. Definitions

In this Section 18, the following defined terms have the associated meanings:

Data Subject has the meaning attributed to that term in the GDPR;
EEA means the European Economic Area;
GDPR means:
1. in respect to residents in the EEA – the General Data Protection Regulation, Regulation (EU) 2016/679 and any legislation and/or regulation implementing or made pursuant to it or which amends or replaces any of them, as it applies to the EEA;
2. in respect to residents in the UK – the UK General Data Protection Regulation under the Data Protection Act 2018 (UK) and any legislation and/or regulation implementing or made pursuant to it or which amends or replaces any of them, as it applies to the UK;
Personal Data has the meaning attributed to that term in the GDPR; and
UK means the United Kingdom.
Compliance with the GDPR
1. In providing our services, or collecting and using your Personal Data, we are required to comply with the GDPR where you are a resident of the EEA or the UK.
2. If you are a resident of the EEA or the UK for the purposes of the GDPR, then the following applies to you in addition to all other provisions of this Policy (and will take precedence to the extent of any inconsistency).
Residents of the UK or the EEA
1. Our products and the Services may be purchased by residents in the UK and the EEA. You may make an enquiry with us, either on your own behalf or on behalf of another. If you are domiciled in the UK or the EEA, your Personal Information is processed by us in Australia. When you submit data, including Personal Information, to purchase our products or Services, that data is being submitted directly into Australia and at no time is held in the UK or any country in the EEA. In such circumstances, we will be considered the controller of such data submitted.
2. We rely on the following provisions of the GDPR when transferring your data to our servers in Australia:
  1. (Article 49(1)(a)): at the time of submitting the data, you explicitly consented to the transfer of your data outside of the United Kingdom or the EEA and into Australia;
  2. (Article 49(1)(b)): the transfer of data into Australia is necessary for the performance of the contract you are entering with us when you submit your data;
  3. (Article 49(1)(c)): the transfer of data into Australia is necessary to conclude a contract between you and us, created when you submit the data; and
  4. (Article 1): to otherwise peruse our legitimate business interests outlined in this policy.
Rights as an EEA or UK Resident
1. As a Data Subject you may:
  1. (access) request access to your Personal Data held by us:
  2. (rectification) request to update or rectify any of the Personal Data that we hold about you by contacting us at the details specified below and request Personal Data updates;
  3. (erasure) withdraw your consent to Become Secure’s use of your Personal Data as described in this policy by deletion or erasure of your Personal Data that we hold where that data is no longer required for the purpose for which it was collected;
2. (restriction on processing) obtain from the controller a restriction on processing of your Personal Data where:
  1. accuracy of the Personal Data is contested;
  2. the processing by the processor is unlawful (and you oppose erasure but request restriction of use);
  3. we no longer needs your Personal Data; or
  4. you have objected to processing pursuant to your right to object under Article 21(1) of the GDPR;
3. (data portability) request that we:
  1. provides you with a copy of the Personal Data that Become Secure holds about you in a portable and machine readable form; or
  2. share your Personal Data with a nominated third party,
4. If we hold your Personal Data, please submit your written request to our representative Privacy Officer using the contact details set out in Section 22 below.
5. We will process your request promptly and in any event, within one month of receipt of receiving it.
6. If you have any concerns in relation to how we collect or process your Personal Data, then you also have a right to complain to a supervisory authority (within the meaning of the GDPR).

Minors

The Become Secure APP is not intended for individuals under the age of 18.

Direct Marketing
1. You give your Personal Information to us set out in clause 4 above to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).
2. Without limiting paragraph 20.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your Personal Information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
Unsubscribe or Opt-out
1. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. When it comes to marketing communications, such as emails, text messages, push notifications, alerts and other messages, you can ask us not to send you these at any time by following the unsubscribe instructions contained in our communication, disable push notifications on your mobile device or make your request from to the Privacy Officer, the details of which are outlined in clause 22 of this Policy.
Contact
1. If you have any comments, concerns or questions regarding this Policy or Personal Information that we hold about you, please contact our Privacy Officer at

Mobile: 0412526571

Email: info@becomesecure.com.au

Post: PO Box 723 Tweed heads, New South Wales 2478 Australia