Privacy Policy Updated 25 May 2018 Introduction We are committed to safeguarding the privacy of your personal data.
We will only collect and use your personal data to:

• Improve our services
• Meet our legal responsibility

This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of your personal data. It covers:

• The personal data we collect
• How we use your data
• How we share your data
• International transfers of your personal data
• Retaining and deleting personal data
• Your rights
• Cookies

The personal data we collect Personal data is information about an individual that can be used to identify that individual. It does not include anonymized data where the personal identification has been removed.
If you are under the age of 13, you are not permitted to use or submit your data.
The groups of data that we collect are:
Usage Data – includes information about your use of our website/app and services, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, how your journey progresses, website/app performance, including information about the timing, frequency and pattern of your service.
Technical Data – includes information about the devices you use to access our services, your internet IP address, browser type and version, operating system, geographical location, time zone settings and location, browser plug-in types and versions.
We collect, use and share aggregated data such as statistical or demographical data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. We will not be able to identify you from this data.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, to protect your vital interests or the vital interests of another natural person. How we use your data The purpose of processing your data:
To improve our business, services, websites/apps including experience, security, data analysis, support, reporting and storage of data including your preferences – Usage, Technical Data for Legitimate interests and Legal Obligations
To deliver relevant website content, online advertisements and information for you and analyse the effectiveness of the content and advertising – Usage, Technical Data for Legitimate interests
To use data to improve our websites/apps, products and services, marketing, customer relationships and experiences including market research, statistical and survey purposes – Usage, Technical Data How we share your data We may disclose and share your personal data with the parties below:
To any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) where necessary for the purposes, and on the legal bases, set out in this policy.
To our insurers and/or professional advisers where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
To our suppliers or subcontractors when necessary for the purposes included in ‘How we use your data’ such as:

• Third party service providers that we engage to provide IT systems and software, and to host our website/apps
• Third party analytics that assist us with understanding how we can improve and optimize our services.

To our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. International transfers of your personal data We and our other group companies have offices and facilities in Australia, New Zealand, USA, England, Russia, Philippines, Singapore, Malaysia. The hosting facilities for our websites/apps are situated in Australia, USA, Germany and Singapore. We have suppliers in Australia, France, USA, UK and Singapore. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. Retaining and deleting personal data Personal data that we process shall not be kept for longer than is necessary for that purpose or those purposes.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
Your rights
You have the following rights in respect of your personal data:

1. the right to access
   You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data.
2. the right to rectification
   You have the right to have any inaccurate personal data about you rectified and to have any incomplete personal data about you completed. You can do this at any time by visiting the My Account section of our websites/apps.
3. the right to erasure
   In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
4. the right to restrict processing
   You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
5. the right to data portability
   To the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6. the right to complain to a supervisory authority
   If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
7. the right to complain to a supervisory authority
   To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
   You may exercise any of your rights in relation to your personal data by using the Contact us link on the websites/apps.

Cookie Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
We use Google Analytics to analyse the use of our website. [Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.] The relevant cookies are:

_ga, _gid, _gat

Managing Cookies
We allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
If you block cookies, you will not be able to use all the features on our website. Credit This document was created using a template from SEQ Legal.