Inauro Pty Ltd, trading as Inauro, ACN 648 996 258 is part of the Inauro group of companies (“Inauro” or “we” ). Inauro takes your privacy seriously and is committed to responsible privacy practices.
We are committed to protecting the privacy of everyone who uses our services, for them to understand what personal information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their personal information in our possession, and with complying with the applicable laws, including the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (“Privacy Act”), the California Consumer Privacy Act (“CCPA”) and the General Data Protection Regulation (EU) 2016.679 (“GDPR”).This policy describes how Inauro manages your personal information including details of what types of personal information Inauro collects, how Inauro collects your personal information, the purposes for which Inauro uses your personal information and to whom your personal information is disclosed.
What types of personal information do we collect?
The types of personal information Inauro collects will depend on the purpose for which the information is collected. The types of personal information that Inauro may collect generally comprises names and contact details.
Inauro may also collect additional personal information such as employment history, date of birth and government related identifiers such as tax file numbers, with respect to contractors and prospective employees.
Generally, Inauro does not collect sensitive information.
Inauro also collects general analytics and other technical information (such as your IP address, device type, unique device identification numbers, browser type, version and language, operating system, geolocation data, browsing preferences, pages viewed while browsing the websites, page access times and referring website address and usage of Inauro’s websites https://www.Inauro.io/ and https://perspio.io/ (Websites) or products) arising from your use of the Websites.
This information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are on our Websites.
In addition to the types of personal information identified above, Inauro may collect personal information as otherwise permitted or required by law.
How do we collect personal information?
Inauro will usually collect your personal information directly from you, including when you:
- use or subscribe to the Websites or use Inauro’s products or services;
- apply to work with Inauro or are engaged by Inauro as a contractor; or
- make inquiries about us or our services or otherwise communicate with Inauro by email, by telephone, in person, via a website or otherwise.
In some cases Inauro may also collect personal information from third parties such as:
- publicly available sources;
- entities with which Inauro conducts business; and
- other third parties (for example, from referees if you apply for a position as an employee or contractor with us).
You may deal with us anonymously or using a pseudonym when you access many aspects of the Websites or making inquiries through the Websites or by telephone, if you do not require a response from us. However, to access Inauro’s customer support features or for us to respond to inquiries, we require certain contact details from you. We generally need your personal information in order to transact with you.
Why do we collect, use and disclose personal information?
In general Inauro collects, uses and discloses your personal information for purposes connected with its business operations.
Inauro will only collect, use, and disclose personal information about you if it has lawful basis to do so, for example:
- where you have given Inauro your consent;
- where processing of your personal information is necessary for the performance of a contract with you;
- to help Inauro manage, develop and enhance its services (including any collaborations or other activities that involve personal I\information and data with third parties);
- to meet Inauro’s legal obligations; or
- to pursue Inauro’s legitimate business interests.
Inauro may use or disclose your personal information (including between its group companies):
- for the purposes for which Inauro collected it (and related purposes which would be reasonably expected by you);
- for other purposes to which you have consented;
- for purposes necessary for the conclusion or performance of a contract;
- in order to sell Inauro’s business (in that Inauro may need to transfer personal information to a new owner); and
- as otherwise authorised or required by law.
Some of the specific purposes for which Inauro collects, uses and discloses personal information include:
- to provide its products and services to its customers or to receive goods or services from third parties;
- to enable the proper operation and functionality of its products and services;
- to improve its products and services;
- to verify your identity (for example, if you request access to the personal information Inauro holds about you);
- to consider you for a job at Inauro (whether as an employee or contractor) or other relationships with Inauro;
- to address any issues or complaints that Inauro has or you have regarding our relationship;
- to comply with its legal obligations;
- to develop and improve the quality of its Websites and products and customise its Websites and products according to your preferences, tailor search results, and show relevant advertising;
- for direct marketing purposes (see the “Direct marketing” section below); and
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
At no point will Inauro sell any of the personal information it has collected.
Inauro will never discriminate against you for exercising your right to privacy under any applicable law.
Specifically, we will not:
- Deny you goods or services;
- Charge you a different price for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level of quality of goods or services.
Note: If Inauro is unable to collect your personal information then Inauro may not be able to provide you with the products, services and opportunities that depend on the collection of that information.
To whom do we disclose personal information?
Inauro may disclose your personal information to third parties in connection with the purposes described above.
This may include disclosing your personal information to the following types of third parties:
- its related companies;
- any potential third party acquirer of Inauro or its business or assets, and advisors to that third party;
- its professional advisers (such as lawyers, accountants or auditors) and insurers;
- its employees, contractors and third party service providers who assist Inauro in performing its functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers;
- organisations authorised by Inauro to conduct promotional, research or marketing activities;
- third parties to whom you have authorised Inauro to disclose your information (e.g. referees); and
- any other person as required or permitted by law.
If Inauro discloses your personal information to third parties, it will ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in Inauro’s agreement with a third party service provider to which Inauro discloses your personal information.
Does personal information leave Australia?
Inauro stores personal information in servers located in Australia as well as through third party service providers located overseas, such as in the United States of America. Inauro may disclose your personal information to recipients, such as to its subsidiaries, related entities, subscribers, resellers and service providers located overseas, in order to provide its products and services and to obtain services. Such overseas recipients may be located in different countries which are likely to include France, the United Kingdom and the United States.
To the extent required by law, Inauro will take reasonable steps to ensure that overseas recipients to whom Inauro discloses personal information do not breach the Australian Privacy Principles stated in the Privacy Act, and any other relevant legislation relating to privacy and data security, in relation to such information.
How do we protect your personal information?
Inauro engages service providers to store your personal information, including Microsoft Azure (Azure), Recurly, Leadpages, Hubspot, Mailchimp and Google. Inauro recommends that you review these companies’ privacy policies to understand how they use and store your personal information.
We use industry standard security measures to safeguard and protect your information.
We may disclose your personal information to companies in the Inauro group, third parties and service providers located overseas in connection with any purpose, including to overseas cloud computing hosts. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s personal information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
If an individual suspects any misuse or loss of, or unauthorised access to, their personal information, they should let us know immediately.
Where we become aware of any breach to our security systems that breaches or is likely to result in a breach of your rights or freedoms with respect to your personal information, we will notify you and any supervisory authority as required.
Except to the extent liability cannot be excluded due to the operation of statute, Inauro excludes all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Policy restricts, excludes or modifies or purports to restrict, exclude or modify Inauro’s obligations under the Privacy Act and/or GDPR, or any other applicable legislation or any statutory consumer rights you may have under any applicable law including the Competition and Consumer Act 2010 (Cth).
Please notify Inauro immediately if you become aware of any breach of security.
Inauro may use and disclose your personal information for the purpose of direct marketing to you if:
- you have consented to Inauro doing so; or
- it is otherwise permitted by law.
Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS. You can unsubscribe from Inauro’s direct marketing, or change your contact preferences, by contacting Inauro (see the “How to contact us” section below) or by clicking on the relevant link at the bottom of any direct marketing emails.
How long do we keep your personal information?
Inauro will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this policy) unless a longer retention period is required by law.
This means that Inauro will store your personal information for the following periods:
- if you unsuccessfully apply for a job at Inauro (whether as an employee or contractor): up to 6 months;
- if you work at Inauro (whether as an employee or contractor): up to 6 years after you cease working with Inauro;
- if Inauro processes your personal information in connection with you being a supplier to Inauro (or an employee or contractor of a supplier) or in connection with you being a subscriber or reseller (or an employee or contractor of a subscriber or reseller): up to 6 years from your last interaction with Inauro; and
- if Inauro processes your personal information for direct marketing purposes or processes your personal information based on your consent, Inauro may process the information until you ask Inauro to stop and for a short period after that (to allow Inauro to implement your request). Inauro will indefinitely keep a record of the fact that you have asked Inauro not to send you direct marketing or to process your information so that Inauro can respect your request in future.
Inauro may retain your personal information for a longer period of time if it is reasonably necessary to comply with Inauro’s legal obligations, resolve a dispute or maintain security.
When personal information is no longer required, Inauro will take reasonable steps to delete the personal information from Inauro’s systems or de-identify the personal information.
How you can seek to access and correct personal information we hold about you:
You may seek access to personal information Inauro holds about you by contacting Inauro as described in the “How to contact us” section below.
Inauro will provide access to that information in accordance with applicable legal requirements, subject to certain exemptions which may apply. Inauro may require that the person requesting access provide suitable identification and where permitted by law Inauro may charge a fee for giving access to your personal information.
If the personal information was provided to Inauro by any of Inauro’s subscribers or resellers, Inauro may advise the relevant subscribers or resellers of your request and liaise with them about it.
If you become aware that any personal information Inauro holds about you is incorrect or if you wish to update your information, please contact Inauro as described in the “How to contact us” section below.
In the event that you decide that you no longer want us to hold your personal information, you may notify us in writing of your desire for us to delete your personal information on record. We will use our best endeavours and comply with all legal requirements within a reasonable timeframe to delete your personal information, unless we are required by law to retain such information.
How you can complain about a privacy issue
You may make a privacy complaint in relation to personal information Inauro holds about you by contacting Inauro as described in the “How to contact us” section below.
If you make a privacy complaint, Inauro’s Privacy Officer or another suitable staff member of Inauro will investigate the matter and attempt to resolve it as soon as reasonably possible (usually within 30 days of receipt of the complaint).
If you consider your concerns have not been resolved satisfactorily by Inauro, or you wish to obtain more information
- the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au; and
- if you are located in the European Union, your local data protection authority: https://edpb.europa.eu/about-edpb/board/members_en.
Individuals located in the EU
If you are:
- a resident of the European Union receiving our services in Australia; or
- receiving our services from within the European Union,
then in addition to our obligations under the Privacy Act, Inauro is required to comply with the GDPR with respect to your personal information.
Individuals located in the state of California, United States of America
If you are:
- a resident of the state of California receiving our services in Australia; or
- receiving our services from within the state of California,
then, whilst Inauro is not legally required to comply, in addition to our obligations under the Privacy Act, Inauro complies with CCPA with respect to your personal information.
Local exemptions and inconsistency with law
Where local laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption in Australia), Inauro may rely on such an exemption.
This policy will not apply to the extent that it is inconsistent with any applicable law.
Changes to this policy
Inauro may change this Policy from time to time at its discretion. Amendments to this policy will be posted on the Websites. Your continued dealings with Inauro, for example use of its websites, products or services, will signify your agreement to this policy as amended.
We use “cookies” and similar tracking technology, such as web beacons and authentication tokens on our websites. A “cookie” is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser, but not you.
Cookies can be “persistent” (cookies that stay on your browser until you delete them or else your browser deletes them based on the duration period set in the cookie) or “session” (cookies which are erased when you close your browser). Inauro uses session cookies and persistent cookies on the Websites.
If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our websites, but it may impact your user experience of the websites.
Such information does not refer to individuals by name or their contact details. We use this data in aggregate to improve our websites and our goods and services. We may provide such aggregated data to third parties, but in so doing, we do not provide personal information without the individual’s consent.
How to contact us
If you have a query, concern or complaint about the manner in which your personal information has been collected or handled by Inauro or would like to request access to or correction of the personal information Inauro holds about you, please contact Inauro’s Privacy Officer via email to firstname.lastname@example.org or by post to:
Attn: Privacy Officer,
PO Box 1057
North Sydney 2059
If you are in the EU, or the state of California, USA, and have a query, concern or complaint, or wish to access, correct or delete your personal information, please contact email@example.com.