Privacy Policy

Last updated: 20 December 2023

Privacy Policy

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Circular Economy Systems Pty Limited (ABN 32 623 565 471). We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act)

By providing personal information to us, you consent to our collection, use, storage and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your bank or credit card details.

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with us (for example, by communicating with us, using our services, or attending our events either online or in person), unless a different policy is displayed. We offer a wide range of products, including websites and applications. We refer to all of these products, together with our other services and websites, as “Services” in this policy.

This policy also explains how we use information about you, which includes how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

What personal information do we collect?

We may collect the following types of personal information:

  • name;
  • mailing or street address;
  • email address;
  • telephone number and other contact details;
  • age or date of birth;
  • a copy or details of identification documents (for example, passport, driver’s licence, etc.);
  • bank account details;
  • information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, standard web log information, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services;
  • details of your previous transactions and dealings through our website and applications;
  • details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries;
  • information about you when you register for an account, create or modify your profile, set preferences, or sign-up for the Services;
  • content you provide through our Services you use, including content that you post, send, receive, share or submit;
  • information you provide through our support channels, where you may choose to submit information regarding a problem you are experiencing with a Service;
  • information about you when you use our Services, including browsing our websites and taking certain actions within the Services;
  • information about you when you visit and interact with any of our Services. This information includes the features you use, the links you click on, the type, size and filenames of attachments you upload to the Services, frequently used search terms, and how you interact with others on the Services;
  • information we collect automatically when you use the Services;
  • cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices;
  • information about you from other Service users, from third-party services, including from our related companies, and public databases, and in some cases from our business and channel partners. We may combine this information with information we collect through other means described above. This helps us to update and improve our records and Services, suggest services that may be of interest to you, or assist with making a complaints;
  • information from other users of the Services about you when they submit content through the Services. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as a contact on your company's account or when they designate you as an administrator;
  • information about you when you or your administrator integrate third-party service with our Services. For example, if you create an account or log into the Services using your Microsoft or other third party credentials for single sign on, we receive your name and email address as permitted by your Microsoft or other third party profile settings in order to authenticate you. You or your administrator may also integrate our Services with other services you use, such as to allow you to access, store, share and edit certain content from a third-party through our Services. For example, you may authorise our Services to access, display and store files from a third-party document-sharing service within the Services interface;
  • information about you and your activities on and off the Services from third-party partners, such as analytics partners who provide us with information about your interest in and engagement with, our Services and our marketing materials and programs;
  • information about you from third party providers of business information and publicly available sources (like social media platforms or the Australian Business Registry), including ABNs, equity type, physical mail addresses, job titles, email addresses, phone numbers, and IP addresses and in some cases social media profiles, for the purposes of targeted advertising of Services that may interest you, delivering personalized communications, event promotion, and related profiling;
  • any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence, including information communicated to a chatbot on our website, or through other websites or accounts from which you permit us to collect information; and
  • any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

  • register an account through one of our websites or applications;
  • communicate with us through correspondence, chats, a chatbot, email, our or others’ contact centres, or when you share information with us from other social applications, services or websites; or
  • interact with our sites, Services and content.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

Why do we collect, use and disclose personal information?

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

  • to provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate, maintain, and improve the Services;
  • to provide customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services. Where you give us express permission to do so, we share information with a third party expert for the purpose of responding to support-related requests;
  • to verify your identity;
  • to enable you to access and use, and monitor your use of, our website and applications;
  • for research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and usefli. We use information and collective learnings (including feedback) about how people use our Services to troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Services and to develop new products, services, features and technologies that benefit our users and the public;
  • to operate, protect, improve and optimise our website and applications, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  • to facilitate your participation in beverage container refund schemes, including allowing you to collect, deposit, receive payment for, buy or sell, containers as part of a beverage container refund scheme;
  • to communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including responding to your comments, questions and requests, providing customer support, and sending you reminders, technical notices, updates, security alerts, and service, support and administrative messages, and information requested by you. We may send you email notifications when you or others interact with you on the Services;
  • to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
  • to protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regliatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business;
  • for safety and security: We use information about you and your Service use to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudlient or illegal activity, including violations of Service policies; and
  • to consider your employment application.

We may also disclose your personal information to trusted third parties, for the purposes set out in this Privacy Policy, and these third parties may also hold other information about you. These third parties may also combine that information in order to enable us to provide the Services, and them and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You may opt-out of receiving marketing materials from us by using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us by emailing [email protected]

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this privacy policy to:

  • other Service users and third parties when you use the Services;
  • our employees;
  • third party suppliers and service providers for the operation of our websites and/or our business or in connection with providing our Services to you;
  • professional advisers, dealers and agents;
  • payment systems operators (including merchants receiving card payments, financial institutions processing electronic funds transfer transactions);
  • our existing or potential agents, business partners or partners. These partners may provide consulting, sales, support, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localised support, and to provide customisations;
  • our sponsors or promoters of any marketing campaign or competition that we conduct via our services;
  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • any participant in a beverage container refund scheme within Australia;
  • specific third parties authorised by you to receive information held by us;
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law;
  • third parties that help us operate, provide, improve, integrate, customize, support and market our Services;
  • other service providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you;
  • links to third party sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit;
  • third party services: We may offer you the ability to interact with or share information with third parties through the Services. For example, we may offer users the ability to log in to the Services via a third-party service like Google, access embedded maps through Google Maps or interact with social media networks via links on the Services. When you intentionally interact with these third parties, we may share certain information with those third parties or receive information with those third parties, consistent with your privacy settings on the third-party service. Such information may include contact information, identification, and demographic information, and device information and identifiers. You should always check the privacy settings and notices in these third-party services to understand how those third-parties may use your information;
  • third party widgets: Some of our services may contain widgets and social media features, such as the Twitter "tweet" button or Facebook "like" button. These widgets and features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third-party or hosted directly on our Services. You should always check the privacy settings and notices in these third-party services to understand how those third-parties may use your information;
  • other persons for compliance with enforcement requests and applicable laws; enforcement of our rights: We may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our Services, (d) protect us, our suppliers, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person;
  • other entities for novation or business transfers: We may share or transfer information we collect under this privacy policy in connection with any novation, merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company; and/or
  • other persons, as necessary to facilitate our dealings with you.

How long we keep information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will de-identify or destroy your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until de-identification or destruction is possible.

  • Account information: We may retain your account information, including in case you decide to re-activate the Services. We also retain your information as necessary to comply with our legal obligations and obligations to third parties, to resolve disputes, to enforce our agreements, to support business operations, and to continue to provide, develop, and improve our Services.
  • Information you share on the Services: If your account is deactivated or disabled, some or all of your information and the content you have provided will remain in order to allow your team members, other users, and other applicable third parties, to make full use of the Services and to the extent that we are permitted to retain such information by, or in connection with, our agreements with third parties.
  • Marketing information: We retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Disclosure of personal information outside Australia

We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services.

We may disclose personal information outside of Australia to our third party suppliers and service providers located in overseas countries, including but not limited to the Philippines, India, Singapore, the United States, Canada, the United Kingdom and New Zealand.

We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. These include using encryption technologies and deploying anti-malware and anti-virus software. However, we cannot guarantee the security of your personal information.

Data protection

We use industry standard technical and organizational measures to secure the information we store. While we implement safeguards designed to protect your information, no security or backup system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that information, during transmission through the Internet or while stored on or used in our Services or otherwise in our care, is absolutely safe from intrusion by others.

If you use our Services, responsibility for business continuity, disaster recovery and backup of your information you provide to or receive from the Services rests with you and not us.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the details set out below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

Our policy towards individuals under 18

The Services are not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If we become aware that an individual under 18 has provided us with personal information, we will, to the extent permitted by law and our agreements with third parties, take steps to delete such information. If you become aware that an individual under 18 has provided us with personal information, please contact us using the details set out below.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below: Privacy Policy Officer [email protected]