Scalare Partners Privacy Statement
Last updated: 1 July 2021
All references to “Scalare”, “Scalare Partners”, “we”, “us” or “our” in this policy are references to Scalare Partners Pty Ltd. This Privacy Statement describes how we collect, receive, use, store, share, disclose and process your personal information. It also describes your choices regarding use, as well as your rights of access and correction of your personal information.
Be assured that we never take your privacy for granted, and because we are guided by privacy laws, you can be sure we take your rights seriously.
How We Collect Personal Information
Generally, we collect an individual’s personal information from that individual. For example, we gather contact information (name, email address) and job classifications through our online forms. We may also collect personal information from someone other than the individual, for example from the company with whom you work.
How We Hold Personal Information
We take reasonable steps to keep secure any personal information that we hold about you and to protect your personal information from loss, misuse, or unauthorised alteration. Access to personal information is limited to those personnel who specifically need it to carry out their business responsibilities. We do not disclose your information to third parties, unless they are related entities or services providers, in which case they are required to conform to our procedures.
We take reasonable steps and precautions to keep personal information secure from loss, misuse, and interference, and from unauthorised access, modification or disclosure. If you use the Internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the Internet. Scalare Partners does not have control over information while in transit over the Internet and we cannot guarantee its security.
When we obtain personal information about you, we ensure that you have our contact details and that you are aware of the collection of information and our purposes for doing so. As per above, we are unable to provide certain services if the requested information is not provided.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Where information is no longer required to be held or retained by Scalare Partners for any purpose or legal obligation, we will take all reasonable steps to destroy or de-identify the information accordingly.
Use and Disclosure of Personal Information
We use and disclose the personal information we collect for the primary purpose for which it is collected as set out in this statement and in any other circumstances authorised by applicable law, including the Australia Privacy Act the New Zealand Privacy Act.
We usually disclose the personal information we collect to our related entities, vendors and service providers (such as IT service vendors, website hosting facilities, and email distribution services) and Business Partners who help us supply our products and services.
We collect personal information so we can:
Provide relevant services to you and others
Match your profile and skills to relevant sources and services
Identify our customers, potential customers, and their representatives
Inform you of any initiatives we think may be of interest to you
Inform you or others about our products and services and the benefits of using our products and services
Provide you or others with information about offers or other benefits that may become available
Seek your opinion or comments about our products and services.
Carry out billing and/or debt recovery activities
Carry out our management, administrative quality assurance and complaint handling activities in a professional and efficient manner
Develop and implement initiatives to improve our products and services
Automatic Data Collection
We do not sell your personal information. When you visit our website or open our emails, we and our third-party partners, such as advertising networks, social media widgets, and analytics providers, collect certain information by automated means, such as cookies, web beacons and web server logs.
We may use this information, for example, to determine how many users have visited certain pages or opened messages or newsletters. We may link this data to your profile. Our partners also may collect and combine information collected on our website and emails with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same partners. The information collected by automated means (such as cookies, web beacons and web server logs) includes online identifiers (such as IP address and device IDs), website activity information (such as website clicks, content and page views, the website each visitor visited prior to our website, browser type), and inferences about your browsing behaviour and interests created from the information listed above.
Cookies & Advertising Partners
We use third-party advertising services to serve advertisements on our behalf. When you visit our website and other websites the third-party analytics services help us understand and improve the usage of our website and the effectiveness of our marketing efforts. In some situations, we allow access to your information to enable the delivery of online advertising to you and others on our website and on other websites and online services from us and our third-party advertising partners, or to send you information we think may be useful or relevant to you.
You may be able to opt-out of receiving personalised advertisements on this browser or device from advertisers, or other advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioural Advertising by visiting the opt-out options of each of those organisations. Links to those websites are here: Network Advertising Initiative: http://www.networkadvertising.org/choices/ Digital Advertising Alliance: http://www.aboutads.info/choices/
You may be able to change browser settings to block and delete cookies when you access our website through a web browser. When you opt out of personalised advertising, you may continue to see online advertising on our website and/or our ads on other websites and online services.
We may use personal information to advise the individual concerned about new products and marketing initiatives that we think may be of interest to them. This may include product and service offerings, newsletters, and general information about us. Those who prefer not to receive information about our products and services can ask to be removed from the relevant circulation list by contacting us at firstname.lastname@example.org.
If you post information on our social media pages, we may collect personal identifiers and characteristics (such as your social media profile). Note that the third-party operators of social media websites also receive such information, and their use of your personal information is governed by their own privacy policies.
Your Privacy Rights
Certain jurisdictions have specific legal requirements and grant privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete the personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. You may be able to use the Service to access and update the information that you have provided to us through your use of the Service or otherwise.
When you make a request, we may require that you provide information and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request. We will match the information that you provide in your request to the information we already have on file to verify your identity. If we can verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Privacy Rights under the Australia Privacy Act and the New Zealand Privacy Act
This section applies to the personal information of individuals in Australia and New Zealand.
Access: If at any time you want to know what personal information we hold about you, you are welcome to request access to that information by contacting us, using the details listed below.
We may deny your request for access where:
The access impacts the privacy or safety of others
The request for access is frivolous or vexatious or the information requested is trivial
There are existing or anticipated legal proceedings
Such access can be denied under the Australia Privacy Act or the New Zealand Privacy Act (as applicable) or under any other applicable law or by a law enforcement agency
If we deny your request for access, we will let you know why. If the New Zealand Privacy Act applies to your request, you have the right to make a complaint to the Privacy Commissioner of New Zealand in respect of our refusal.
Quality & Correction: At all times we strive to ensure that the information we hold about you is accurate, complete, up to date and not misleading. If at any time you believe the personal information that we hold about you is incorrect, incomplete, or inaccurate, you should let us know at email@example.com. We will use all reasonable efforts to correct the information.
EU General Data Protection Regulation
In accordance with the data protection requirements in the European Union General Data Protection Regulation (EU GDPR), we provide the following additional measures that we have adopted in relation to all EU clients and third parties:
We will limit the processing, collection and retention of data to the extent legally possible and practically viable.
We will not request or collect data that is not required for the purpose of providing our services or meeting our legal obligations.
We will delete your information, and acknowledge your right of erasure or to be forgotten, as soon as we are legally able and subject to our other legal and regulatory obligations regarding record-keeping.
You may advise us at any time that you withdraw any consent previously given to us, and require us to stop processing your data.
You may object to any decision based on automated processing, and you may request a manual review.
You have the right to request a transfer of your personal information, which will be provided in a machine-readable electronic format.
Where we intend to process/utilise your personal data beyond the disclosed legitimate purpose for which it was collected, we will obtain clear and explicit consent from you (which can be withdrawn at any time).
We will maintain a Personal Data Breach Register, and notify the relevant regulator in a timely manner as required.
We ensure that organisational and technical mechanisms are utilised to protect personal data when we are designing new systems and processes.
We will conduct Data Protection Impact Assessments when initiating a new project/change/product which involves significant changes to the processing of personal information.
We ensure our representatives are regularly trained regarding our obligations and their responsibilities under applicable privacy/data protection regulations.
Cross-Border Data Transfers
Where necessary and in accordance with privacy laws, we may need to transfer your personal information to another country. Such transfers take place to enable us to provide you with our products and services, for marketing purposes and customer relationship management purposes. We will only make such transfers of your personal information internationally in compliance with the Australia Privacy Act and New Zealand Privacy Act (as applicable) and other applicable laws.
Owner and Data Controller
7/10 Spring Street, Sydney NSW 2000, Australia
If you have any questions relating to this privacy statement or your privacy rights please contact us.