6Clicks Trading Pty Ltd ACN 634 263 166 (6Clicks) takes your privacy seriously and is committed to responsible privacy practices.
6Clicks seeks to comply with relevant laws, including the Privacy Act 1988 (Cth) (Privacy Act) and the EU General Data Protection Regulation (GDPR), where applicable.
This policy describes how 6Clicks manages your personal information including details of what types of personal information 6Clicks collects, how 6Clicks collects your personal information, the purposes for which 6Clicks uses your personal information and to whom your personal information is disclosed.
What is personal information?
In this policy “personal information” has the meaning set out in the Privacy Act. Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.
What types of personal information do we collect?
The types of personal information 6Clicks collects about you will depend on the purpose for which the information is collected. 6Clicks may collect the following types of personal information:
– first name and last name; and
– email address.
6Clicks also collects general analytics and other technical information (such as your IP address, device type, unique device identification numbers, browser types, Internet Service Provider details, geolocation data, browsing preferences, searches, and usage of 6Clicks’ websites or products) arising from your use of 6Clicks’ websites or products.
In addition to the types of personal information identified above, 6Clicks may collect personal information as otherwise permitted or required by law.
How do we collect personal information?
Often 6Clicks will collect your personal information directly from you, including when you:
– use 6Clicks’ website, products or services;
– apply to work with 6Clicks or are engaged by 6Clicks as a contractor;
– communicate with 6Clicks by email, by telephone, in person, via a website or otherwise.
In some cases 6Clicks may also collect personal information from:
– publicly available sources;
– entities with which 6Clicks conducts business; and
– other third parties (for example, from referees if you apply for a position as an employee or contractor with us).
Why do we collect, use and disclose personal information?
In general 6Clicks collects, uses and discloses your personal information for purposes connected with its business operations.
6Clicks will only collect, use, and disclose personal information about you if it has lawful basis to do so, for example:
– where you have given 6Clicks your consent;
– where processing of your personal information is necessary for the performance of a contract with you;
– to meet 6Clicks’ legal obligations; and
– to pursue 6Clicks’ legitimate business interests.
6Clicks may use or disclose your personal information:
– for the purposes for which 6Clicks collected it (and related purposes which would be reasonably expected by you);
– for other purposes to which you have consented; and
– as otherwise authorised or required by law.
Some of the specific purposes for which 6Clicks collects, uses and discloses personal information are as follows:
– to provide its products and services to its users;
– 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 6Clicks holds about you);
– to consider you for a job at 6Clicks (whether as an employee or contractor) or other relationships with 6Clicks;
– to provide goods or services to you or to receive goods or services from you;
– to address any issues or complaints that 6Clicks 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.
If 6Clicks is unable to collect your personal information then 6Clicks 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?
6Clicks 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 6Clicks 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 6Clicks in performing its functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, telecommunications providers and IT support services providers;
– organisations authorised by 6Clicks to conduct promotional, research or marketing activities;
– third parties to whom you have authorised 6Clicks to disclose your information (e.g. referees); and
– any other person as required or permitted by law.
If 6Clicks discloses your personal information to third parties it will use reasonable commercial efforts to 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 by (where commercially practical) including suitable privacy and confidentiality clauses in 6Clicks’ agreement with a third party service provider to which 6Clicks discloses your personal information.
Does personal information leave Australia?
6Clicks stores personal information in servers located in Australia. However, 6Clicks may disclose your personal information to overseas recipients, such as to subscribers, re-sellers and service providers located overseas, in order to provide its products and services and to obtain services. Such overseas recipients may be located in a large number of different countries which are likely to include the UK, USA, Germany, France and other EU countries, Singapore, and New Zealand. It is not practical for 6Clicks to list every country where such overseas recipients may be located.
Except where an exception applies under the Privacy Act or other relevant legislation, 6Clicks will take reasonable steps to ensure that overseas recipients to whom 6Clicks 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?
6Clicks engages service providers to store your personal information, including Microsoft Azure and Azure Storage. 6Clicks recommends that you review these companies’ privacy policies to understand how they use and store your personal information.
6Clicks will take reasonable steps to keep any personal information it holds about you secure.
However, you acknowledge that the security of personal information transmitted over the internet cannot be guaranteed. 6Clicks cannot guarantee that any personal information you disclose to 6Clicks will not become publicly available. Except to the extent liability cannot be excluded due to the operation of statute, 6Clicks 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 6Clicks’ obligations under the Privacy Act and 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 6Clicks immediately if you become aware of any breach of security.
6Clicks may use and disclose your personal information for the purpose of direct marketing to you if:
– you have consented to 6Clicks 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 6Clicks’ direct marketing, or change your contact preferences, by contacting 6Clicks (see the “How to contact us” section below).
How long do we keep your personal information?
Generally, 6Clicks 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 6Clicks will store your personal information for the following periods:
– if your personal information is provided to 6Clicks by a subscriber or re-seller: only for so long as 6Clicks requires it for the purpose of its agreement with the subscriber or re-seller;
– if you unsuccessfully apply for a job at 6Clicks (whether as an employee or contractor): up to 6 months;
– if you work at 6Clicks (whether as an employee or contractor): up to 6 years after you cease working with 6Clicks;
– if 6Clicks processes your personal information in connection with you being a supplier to 6Clicks (or an employee or contractor of a supplier) or in connection with you being a subscriber or re-seller (or an employee or contractor of a subscriber or re-seller): up to 6 years from your last interaction with 6Clicks; and
– if 6Clicks processes your personal information for direct marketing purposes or processes your personal information based on your consent, 6Clicks may process the information until you ask 6Clicks to stop and for a short period after that (to allow 6Clicks to implement your request). 6Clicks will indefinitely keep a record of the fact that you have asked 6Clicks not to send you direct marketing or to process your information so that 6Clicks can respect your request in future.
6Clicks may retain your personal information for a longer period of time if it is reasonably necessary to comply with 6Clicks’ legal obligations, resolve a dispute or maintain security.
When personal information is no longer required, 6Clicks will take reasonable steps to delete the personal information from 6Clicks’ 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 6Clicks holds about you by contacting 6Clicks as described in the “How to contact us” section below.
6Clicks will provide access to that information in accordance with applicable legal requirements, subject to certain exemptions which may apply. 6Clicks may require that the person requesting access provide suitable identification and where permitted by law 6Clicks may charge a fee for giving access to your personal information.
If the personal information was provided to 6Clicks by any of 6Clicks’ subscribers or re-sellers, 6Clicks may advise the relevant subscribers or re-sellers of your request and liaise with them about it.
If you become aware that any personal information 6Clicks holds about you is incorrect or if you wish to update your information, please contact 6Clicks as described in the “How to contact us” section below.
How you can complain about a privacy issue
You may make a privacy complaint in relation to personal information 6Clicks holds about you by contacting 6Clicks as described in the “How to contact us” section below.
If you make a privacy complaint, 6Clicks’ Data Protection Officer or another suitable staff member of 6Clicks will investigate the matter and attempt to resolve it as soon as reasonably possible.
If you consider your privacy concerns have not been resolved satisfactorily by 6Clicks, or you wish to obtain more information on privacy requirements:
– you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at oaic.gov.au; and
– if you are located in the European Union you can contact your local data protection authority: https://edpb.europa.eu/about-edpb/board/members_en.
Individuals located in the EU
If you are located in the European Union, you may have the following rights:
– The right to access, rectify or update the personal information 6Clicks holds about you.
– The right to request erasure of personal information 6Clicks holds about you, for example if the personal information is no longer necessary to provide services to you.
– The right to require 6Clicks to stop using all or some of your personal information (for example, if 6Clicks no longer has a legal right to keep using it) or to restrict its use of your personal information (for example, if you consider that the personal information 6Clicks holds about you is inaccurate or if it is unlawfully held).
– The right to data portability. In some circumstances you have the right to be provided with a copy of the personal information 6Clicks has about you in a structured, machine-readable and commonly used format.
– The right to withdraw consent. You may withdraw your consent at any time where 6Clicks relied on your consent to process your personal information.
6Clicks may ask you to provide suitable identification when you seek to exercise any of these rights.
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), 6Clicks 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
6Clicks may change this policy from time to time at its discretion. This policy was last updated in August 2019. If 6Clicks makes further updates to this policy, 6Clicks will post the amended policy on its websites. Your continued dealings with 6Clicks, for example use of its websites, products or services, will signify your agreement to this policy as amended.
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 6Clicks or would like to request access to or correction of the personal information 6Clicks holds about you please contact 6Clicks’ Data Protection Officer via email to [email protected].