10th October 2021
Privacy Policy
Our Privacy Statement explains how we collect, store, use and share your personal information.
This Privacy Statement applies to products and services produced by Adapt21 Pty Ltd (‘we’, ’us’ or ‘our’ in this Privacy Statement). We have identified where parts of this Privacy Statement also apply when you use specific Adapt21 products and services.
These current statements came into effect at 10th October 2021. We may need to update it from time to time, however if we do then we will post the updated version on this internet web page.
Our definition of information gathered and information collected
We make a distinction between information gathered and information collected by our products and services.
Information gathered
We define information gathered as information that you supply, or information that is derived by one or more of our products and services that run on smartphones and other devices. The information that is gathered is stored on the device upon which the information was gathered. Where information is gathered, it is not automatically sent to us meaning we do not collect this information.
Information collected
We define information that we collect as information that you supply, or information that is derived by one or more of our products and services that run on smartphones and other devices, AND whereby we have explicitly notified you that we will be collecting the information. Where information is collected it may be transmitted to Adapt21 Pty Ltd. If we do not notify you explicitly within the product or service that we would like to collect your information or information derived then it not be transmitted from your device through the use of our products or services.
What information do we gather? What information do we collect?
The types of personal information we collect about you depends on which of our products and services you use, how you use those products and services, and our relationship with you. Generally speaking, even though our products gather information from you, that information is not shared with us and remains upon the device in which the information was gathered (unless otherwise called out as information collected).
Generally, we may gather the following types of information whilst you use our products and services:
Our products and services may gather information relating to the device you use. Our products and services may also gather information such as location (longitude and latitude) information and permission to provide notifications to you on your device, if you consent to this.
We may collect the following types of information from you, about you:
Information we may need to verify your identity, provide you with our products and services, and communicate to you about them such as your name, date of birth, contact details (including address, email address, phone number or mobile telephone number), username and password.
Financial and credit information: We do not gather or collect any information relating to your income details, payment history, or credit history.
Sensitive information: We do not collect any information relating to your race, ethnic origin, health, social or society status. We will seek your consent before we collect and use sensitive information about you, unless we are permitted or required to do so by law.
Information about when and how you use Adapt21 websites & smartphone applications: You might also (optionally) choose to provide personal information about other individuals when using specific Adapt21 smartphone applications in order for those applications to provide you with the greatest level of functionality. However, we will not ask you to share information with us about other individuals. If you do decide to provide personal information about other individuals within one of the applications produced by Adapt21 then we rely on you to tell those individuals that you are using their personal information and tell them about this Privacy Statement.
Depending on the Adapt21 products and services you use, we may also gather and collect Information about how you use our products and services such as:
The frequency in which you use our products and services
The location (latitude and longitude) at the time of your use of our products and services on your device
How do we collect your information?
Depending on the specific products and services used, we would gather and collect information when:
You give it to us through interfacing/using with one of our products or services where we have expressly notified you requesting your permission that the information can be shared with us.
You provide permission for information gathered or derived from within our products and services upon your device(s) such as location information, Adapt21 application usage.
How do we store your personal information?
Information that is gathered when using our products and services is stored on your device using your devices storage algorithms and any device encryption technologies that are either native or have been installed by you on your device. Information that is collected by us may be stored in a digital and / or hard copy format and kept in storage facilities that we own and operate ourselves or that are owned and operated by our service providers. Where we collect information we use a combination of technical solutions, security controls and internal processes to help us protect information from unauthorised access and disclosure.
We aim to ensure that any personal information collected is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably possible. However, we might need to keep some personal information for a longer period of time to comply with any legal obligations that could arise from time to time.
How do we use your information?
For clarity, we only use information collected (where you have provided permission for us to collect). We will use that information to:
To provide relevant products and services – We use information collected to provide any additional relevant products and services to you and to enable us to conduct our business.
Administration – We will use your personal information (if / when supplied to us by you) to help us properly manage the products and services we provide to you, deal with your enquiries.
Communication – We will use personal information (if / when supplied to us by you) to communicate with you to provide you with information relating to our products and services. We might do this via phone, email, SMS, social media.
Improvement – We are constantly working to not only maintain and improve our products, services and processes but to develop new ones. We may use your information in a number of ways to help us do this (e.g. to monitor our developed application usage, quality and performance, and to operate, maintain, develop, test and upgrade our systems and infrastructure).
Development and analysis – For certain Adapt21 developed applications, it is important we understand how the application(s) are being used, when they are being used, where they are being used (geographic locality). We will apply business intelligence to information we receive that will help us to develop high level insights into things like usage patterns, demographic trends and other types of behavioural data. In many cases, this information is aggregated and de-identified when analysed. We may share these anonymised insights with select business and commercial partners. In some cases, we may create insights with your information on an identified basis but would only do so in compliance with privacy laws.
Direct marketing – We want to make sure that you know about all products, services and special offers of Adapt21 that could be of interest to you. We may use the information we hold about you to market and promote them directly to you. We may also contact you with information about products, services and offers provided by our trusted partners. In some cases, this marketing activity can continue for up to 12 months after you have stopped using our products or services, unless you opt out. Please be aware that if you unsubscribe from our mailing list, we will continue to send you important messages that are not marketing communications, such as important Adapt21 application update information. You can stop Adapt21 using your information for direct marketing or update your marketing preferences by following the unsubscribe instructions in any of our marketing communication.
When do we share your information?
We may share your information with other parties who provide services to us, including suppliers, agents, partners and contractors that assist us with our business processes and provide our products and services. These services include:
Providing, managing or administering your product or service including customer enquiries and support services
Installation, maintenance and repair services
Fraud, crime or misconduct identification, investigation and prevention services
Market research, marketing, and telemarketing services
Development, analysis and business intelligence functions.
We may also disclose your information to:
Other parties when you ask us to do so or when you consent to that disclosure for the purposes of fraud, crime or misconduct identification, investigation and prevention services
Our business or commercial partners and other businesses we work with
Law enforcement and national security agencies, and other government and regulatory authorities as required or permitted by law
Other parties who assist us in managing or developing our business strategies and functions
Other parties as required or permitted by law
Depending on the Adapt21 products and services you use, we may also disclose your personal information to:
Government agencies who are responsible for an emergency alert service (e.g. we may need to provide your information in response to a request by those agencies)
Where we do this, we require these parties to take appropriate measures to protect that information and to restrict how they can use that information.
How can you access or correct your personal information?
To ensure that we can provide you with the best products and services possible, it’s important that you make sure the personal information we hold about you is accurate, up-to-date and complete. You also have the right to request a copy of your information that we hold about you. There is no charge to submit a request or to correct information, however we may charge you an administrative fee for providing access to your personal information on request. If you need to update your details or you wish to access personal information we hold about you, please contact us by emailing us at enquiries@adapt21.com.
How can you contact us?
If you have any questions in relation to this Privacy Statement, our management of your information or you would like a copy of this statement sent to you, please email us at enquiries@adapt21.com