Privacy Policy

Fortiro Pty Ltd (ABN 60 652 862 050) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you. If you are based in the EU or the UK, you may have additional rights, which we have set out at the end of this Privacy Policy.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

As we need to use certain categories of personal information to provide our Services, and for our customers to be able to benefit from those Services, we collect your personal information to the extent that it is reasonably necessary and relevant to the performance of these Services. The types of personal information we may collect about you include:

• Identity Data including your name, age, profession, photographic identification.
• Contact Data including your telephone number, address and email.
• Financial Data including bank account and payment details.
• Verification Data including your proof of income/expense data (such as payslips, bank statements, notice of assessments) and identification details (such as tax file number, passport and/or driver’s licence details) as requested as part of providing our document and data verification services.
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data when you access any of our websites, platforms or emails, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or tracking pixels), and communications with our website.
• Profile Data including your email address used to log into the Fortiro software-as-a-service product and support requests you have made.
• Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience, or whether you hold required authorisations or licences.

In the course of working with you, we may collect, or come across such sensitive information in different situations, including during the course of providing our verification services to our customers. Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

How we collect personal information

We collect personal information in a variety of ways, including:

• when you provide it directly to us, including face-to-face, over the phone, over email, or online;
• when you complete a form, such as registering for any events or newsletters, or responding to surveys;
• when you use any website we operate (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies);
• from third parties; and
• from publicly available sources.

Why we collect, hold, use and disclose personal information

We may collect, hold, use and transfer personal information for the following purposes:

• to enable you to access and use our software, including to provide you with a login;
• to work with you as a customer or supplier of our business, including to maintain system security and stability;
• to contact and communicate with you about any enquiries you make with us via any website we operate;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms;
• for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;
• to run promotions, competitions and/or offer additional benefits to you;
• if you have applied for employment with us, to consider your employment application; and
• to comply with our legal obligations or if otherwise required or authorised by law.

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

• any purposes you consent to;
• the primary purpose for which it is collected;
• secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to work with you as a customer or supplier of our business;
• to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and
• if otherwise required or authorised by law.

Our disclosures of personal information to third parties

Personal information: We will only disclose personal information (excluding sensitive information) to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law. This means that we may disclose personal information (excluding sensitive information) to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers;
• marketing or advertising providers;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• payment systems operators or processors;
• our existing or potential agents or business partners;
• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as analytics providers and cookies; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Sensitive information: We will only disclose sensitive information with your consent or where permitted by law. This means that we may disclose sensitive information to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers;
• professional advisors;
• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as analytics providers and cookies; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

Where we disclose your personal information to third parties, those third parties may store, transfer or access personal information outside of the country where you are based. The level of data protection in countries around the world may be less comprehensive than the data protection laws in your jurisdiction. Where we transfer your personal information overseas, we will perform those transfers using appropriate safeguards in accordance with any privacy laws we are required to comply with, and we will protect the transferred personal information in accordance with this Privacy Policy.

Your rights and controlling your personal information

Your choice: If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to work with you as a customer or supplier of our business.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the relevant regulator in the jurisdiction where you are based. This may include Office of the Australian Information Commissioner (if you are an Australian resident), or the Office of the New Zealand Privacy Commissioner (if you are a New Zealand resident).

Storage and security

We are committed to ensuring that the personal information we collect 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 personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

User-Generated Content

We may enable you to post reviews, comments, photos and other user-generated content. Any content you choose to submit will be accessible by anyone, including third parties not associated with us. We have no control over how others may use or misuse information you make publicly available. We are not responsible for the privacy, security or accuracy of any user-generated content you choose to post or for the use or misuse of that information by any third parties.

Australian Government Document Verification Service (DVS)

How we use the DVS: We use the DVS to verify the authenticity of certain identity documents provided to us and otherwise to provide our services to our clients. We will only collect personal information and use the DVS as required to provide our services, and in accordance with this Privacy Policy.

Your rights: Your rights are set out in further detail in the Your rights and controlling your personal information section of this Privacy Policy.

Consequences of declining consent: Verification through the DVS is an essential part of our identity verification process. If an individual chooses not to consent to our use of the DVS, we may not be able to provide our services to our clients.

Complaints: If you have any concerns about how we handle your personal information in relation to the DVS, you can lodge a complaint by contacting our Privacy Officer using the details provided at the end of this Privacy Policy, as set out in further detail in the Your rights and controlling your personal information section of this Privacy Policy.

Cookies and Analytics

We may use cookies, tracking pixels and similar technologies on our website and in our emails from time to time. Cookies are text files placed in your computer's browser to store your preferences. Tracking pixels are tiny, invisible images (typically the size of one pixel) embedded in web pages or emails. Cookies and tracking pixels, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie or collected by tracking pixels. Unlike cookies, tracking pixels do not store any information on your device, but instead send information to our servers when the pixel is loaded.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

You can block tracking pixels by using ad-blocking or privacy-focused browser extensions. Some email providers allow you to block images by default, which can prevent tracking pixels in emails from loading.

However, if you use your browser settings to block all cookies (including essential cookies) and tracking pixels you may not be able to access all or parts of our website and you may not receive personalised content.

We may use Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here.  To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

To find out how Google uses data when you use third party websites or applications, please see here.

We may use tools provided by Meta, such as the Meta Pixel, advanced matching, and Conversions API. These allow us to measure ad performance and deliver ads that may be relevant to you on Meta platforms based on your activity on our website/app. You can control whether we can join data from third party partners with your Meta account for ads by adjusting your preferences within Meta's settings. You can disconnect this data from your Meta account by changing your settings for Off-Facebook activity. For more information, please see Meta's Privacy Policy here.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles, as well as the New Zealand Privacy Act 2020 and the Information Privacy Principles. In addition to the Australian laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). The Additional rights and Information for Individuals located in the EU or UK section of this Privacy Policy outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.

ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This ‘Additional Rights and Information for Individuals located in the EU or UK’ section sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this ‘Additional Rights and Information for individuals located in the EU or UK’ section carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This ‘Additional Rights and Information for individuals located in the EU and UK’ section applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. The legal bases depend on the services you use and how you use them. This means we collect and use your personal data only where:

• it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;
• it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for the provision of legal services, research and development, to market and promote our services and to protect our legal rights and interests;
• you give us consent to do so for a specific purpose (for example we might ask for consent in order to send you third party marketing materials); or
• we need to process your data to comply with a legal obligation.

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.

Data Transfers

The privacy protections available in the countries to which we send data for the purposes listed above may be less comprehensive than what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and this section. This includes:

• only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
• including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.

For any questions or notices, please contact our Privacy Officer at:

Fortiro Pty Ltd (ABN 60 652 862 050)

Email: admin@fortiro.com