Privacy Policy

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The following document sets forth the Privacy Policy for Gladly: In this Privacy Policy:

• ‘us’, ‘we’, ‘our’ and ‘Gladlyapp’ means Gladly PTY Limited ACN 646 760 974; and
• ‘you’ and ‘your’ means any person registering with us to use our services, accessing our website or otherwise interacting with us.

Gladly is committed to providing you with the best possible customer service experience, which includes respecting your privacy and the personal information you provide to us. Gladly is bound by the Privacy Act 1988, which sets out a number of principles concerning the privacy of individuals.

Please read the following information carefully to understand our practices regarding your personal information and how we will treat it. The “Collecting your personal information” section describes the personal information we may collect from you. We collect this information for the purposes described in the “Using your personal information” section and we share this information as described in the “Sharing your personal information” section. Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, address and contact details. By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and in accordance with any other arrangements that apply between you and us. We may change our Privacy Policy from time to time by publishing updates to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Collecting your personal information

There are many aspects of our website which can be viewed without providing personal information, however, for access to our customer support features and other services, you will be asked to submit personal information. You may at any time refuse to provide the personal information that we request. However, this may limit or prohibit our ability to provide our services to you. You may withdraw your consent for us to process your personal information at any time by contacting us in accordance with our ‘Contacting us’ section below.

We may collect the following types of information about you:

• Information that you provide to us directly

You may provide personal information directly to us in a number of ways, including when you:

• visit and interact with our website or services;
• sign up for an account with us or sign up to our mailing list;
• register to attend one of our events;
• apply for a job with us;
• submit content to us for publication;
• engage in transactions with us;
• provide us with any feedback in connection with your use of our website or services; or
• contact us independently of our website, such as by email, phone or in person.

The personal information you provide to us in these circumstances may include your name, email address, billing address, phone number, the company your work for, your position with that company and other details about that company, and other information needed to allow us to provide our services to you or enable your interaction with us.

• Information that we collect from other sources

We may collect your personal information from other sources, including when you:

• engage or communicate with another entity and agree that they may share your personal information with us;
• register for or attend an event sponsored by us; or
• sign up for an account with us via social login.

The personal information provided to us in these circumstances may include the personal information that you provided to the entity that shared your information or the personal information linked to your social accounts, such as Facebook, Twitter or LinkedIn.

• Device information

Like many websites, when you use our website, we automatically collect certain information about your interaction with our website including information about your web browser, IP address and time zone. Additionally, as you use our website, we collect information about the particular sections of the website that you use and how you interact with the website. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

• “cookies”, which are data files that are placed on your device or computer and often include an anonymous unique identifier;
• “log files”, which track actions occurring on our website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and
• “web beacons”, “tags” and “pixels”, which are electronic files used to record information about how you browse our website.

You can control or reset your cookies through your web browser and, if you choose to, you can refuse all cookies. However, some of the features of our website may not function properly if you disable the ability to accept cookies.

Anonymity

Where possible, we will allow you to interact with us anonymously or using a pseudonym. However, for most of our services, we usually need your name and contact information and enough information to enable us to provide our services to you.

Using your personal information

We use the personal information we collect from and about you for the following purposes:

• Providing our services: We use the information that you give to us to provide our services. This includes allowing you to become a member and to log in to your account, recognising you across different devices and billing you.
• Communicating with you: We use your contact information to send communications to you about important changes or updates to our website or services. When in line with the preferences you have shared with us, we also provide you with information or advertising relating to our services and those of our selected partners.
• Performing data analytics: We use information about you to help us improve our website or services, including by generating analytics about how our members and other users browse and interact with our website, for marketing purposes and to assess the success of our marketing and advertising campaigns.
• Customizing our services for you: We use information about you to make sure that the provision of our website and services is customised to your needs.
• Keeping our website secure: We use information about you to screen for potential risk and fraud and to identify violations of this Privacy Policy and any terms and conditions that apply to users of our website and services from time to time.
• Where required by law: We will use or disclose your information where we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of law enforcement or a government authority; (b) to enforce any agreement we have in place with you or to protect the security and integrity of our website or services; and (c) to exercise or protect the rights, property or personal safety of our business, our users or others.
• Where you have given your consent: We may seek your consent to use your information for a particular purpose. Where you give your consent for us to do this, we will use your information in accordance with that purpose. You can withdraw your consent to these uses at any time.

Unsolicited personal information

If you submit unsolicited personal information to us, we will use it in accordance with this Privacy Policy. Where you submit unsolicited personal information and we determine that we could not have collected the personal information in accordance with this Privacy Policy, we will destroy the information or ensure that the information is de-identified as soon as practicable, if it is lawful and reasonable to do so. Where we retain your unsolicited personal information, it will be handled in accordance with this Privacy Policy.

Sharing your personal information

Outside of the authorized personnel employed by us, we only share your personal information with third parties that meet the data privacy conditions described in this privacy policy. These third parties help us use your personal information for the purposes described above, and include:

• marketing platforms, communications platforms, contractors and other third-party service providers who we engage to help us process personal information and other data, handle customer support enquiries;
• if you conduct a transaction with us that requires payment by you, some of your details may be provided to third parties to allow the transaction to be completed;
• our select partners that we work with when providing our programs and events
• government third parties, including government agencies, regulatory bodies and law enforcement agencies as required, authorised or permitted by law;
• a third party that acquires or intends to acquire us or our assets; and
• other entities if you have given your express consent.

We may also share or disclose your de-identified information (including where aggregated with other individuals’ information) or otherwise non-personal information with third parties for industry or statistical analysis.

International transfers of personal information

Your personal information may be transferred to third parties in countries other than the country in which your personal information was originally collected, including to the United States of America where our hosting provider is located and other countries where our third-party service providers (including Stripe, Inc.) are located from time to time.

These international transfers are made in order to assist us to provide you with, and improve our services and to process transactions made in connection with the provision of our services. When we transfer information to countries other than your own, we take reasonable steps to ensure that the recipients of such information do not breach our Privacy Policy by entering into contractual arrangements with such third parties.

If you are located in the EEA, UK or Switzerland, further information about international transfers of your personal information can be found in the “Residents of the European Economic Area (“EEA”), UK and Switzerland” section below.

Residents of the European Economic Area (“EEA”), UK and Switzerland

If you are located in the EEA, the UK or Switzerland you have certain additional rights under European data protection laws regarding your personal information, including the right to request the deletion and the right to data portability. We are a data controller for the purposes of European data protection laws.

For personal information subject to the European data protection laws, we rely on the following legal bases to process your information:

• where you have given your consent for us to use your information;
• where the processing is necessary to perform a contract that we have with you, for example when you use our services; and
• our legitimate business interests, such as improving and developing our services and marketing new offerings or products (but only where our legitimate interest is not overridden by your interest in protecting your personal information).

In addition, if you are located in the EEA, the UK or Switzerland, we must ensure that international transfers of your personal information comply with European data protection laws. The European Commission has the power to determine, on the basis of the European data protection laws, whether a country outside the European Union offers an adequate level of data protection by making an ‘adequacy decision’. To date, the European Commission has not adopted an adequate decision in respect of Australia. Instead, we rely on other legal bases to lawfully transfer personal information around the world (including transfers to countries like Australia where an adequacy decision has not been adopted), including asking for your consent or transferring personal information subject to European Commission-approved contractual terms.

If you are unhappy with our data practices, you also have a right to lodge a complaint with your local supervisory authority. For more information, you can contact the Office of the Data Protection Commissioner. If you are located in the UK, you may direct your questions or complaints to the UK Information Commissioner’s Office.

Direct marketing

We and our selected partners may send you direct marketing communications and information about services or products that we think you might be interested in. This may take the form of emails, SMS, mail or other forms of communication in accordance with the Spam Act 2003 and the Privacy Act 1988. You may opt out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

Handle Collection and Usage

We collect and store the handles that users choose to identify themselves on the platform. This information is used to allow users to identify and communicate with each other within the platform. We may use handles for the purposes of marketing or advertising, but only if we have obtained the user's express consent. We may also use handles to enforce our terms and conditions, such as in cases where a user's handle violates our intellectual property policies or community guidelines. We do not share handles with third parties except as required by law or as necessary to provide services on our platform.

Changes to this Privacy Policy

Gladly reserves the right to make amendments to this Privacy Policy at any time. Any amendments to this Privacy Policy will be effective upon the publication of the updated Privacy Policy. In all cases, your continued use of our website and services after the publication of any amended Privacy Policy indicates your acceptance of the terms of the amended Privacy Policy. If you have objections to the Privacy Policy, you should not register or share your personal information.

Accessing, changing or deleting your personal information

You have a right to access your personal information, subject to exceptions allowed by law.

You may update certain account information such as your name and email address by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us at any time by clicking on the “unsubscribe link” in the relevant communication.

You may also access, review, update, rectify or delete your personal information that is not available via your account by contacting us. We will respond to all requests within 30 days. Please note that deleting your personal information may limit our ability to provide our services to you. In certain circumstances, we may limit or reject a request to access, review, update, rectify or delete your personal information where required or permitted by law.

If you need further assistance regarding your access and control of your personal information, please contact us via one of the methods set out in the ‘Contacting us’ section below.

Links to third-party websites

Our website may contain links to the websites of other entities. If you click on such links, you will be transferred to the website of these entities. We have no control over and are not responsible for, the privacy practices of these entities. You should read the privacy policy of these entities to find out how they handle your personal information when you visit their websites.

Data retention

We will maintain your personal information for our records because we need this information to operate the accounts you have with us, to deliver our services to you and for the other purposes set out in the ‘Using your personal information’ section. We will retain this personal information for as long as is necessary for the purposes for which it is being processed, in accordance with this Privacy Policy or where we are otherwise required by law to retain it.

Storage and security of your personal information

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it (including encryption and password protection).

However, no method of transmission over the Internet using industry-standard technology is 100% secure. Therefore, we cannot guarantee the absolute security of your information.

Contacting us

Gladly welcomes your comments or questions regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means.

Phone +61 2 9070 0781
info@gladlyapp.com 



If you are an Australian resident and are unhappy with how we handle your complaint or are concerned that we have not complied with your legal rights or applicable privacy laws, you can also contact the Office of the Australian Information Commissioner and make a complaint at https://www.oaic.gov.au/privacy/ privacy-complaints/ or by writing to:

Director of Compliance  

Office of the Australian 

Information Commissioner
GPO Box 5218 

Sydney NSW 2001

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