Effective: 14 August 2018
This Policy is subject to change at our discretion. The current version will always be available on our Website.
Icosian collects Personal Information
Subscribers and Users communicate and exchange Data with Icosian and other Subscribers and Users in connection with their business relationship with Subscribers, Users and Icosian and our Service. The Service involves the storage of Data about You and other Users, that Data can include Personal Information, including:
- personal details, including names and contact details;
- financial and legal information; and
- information necessary for or incidental to the provision of the Service.
“Personal Information” is information about an identifiable individual, and may include information such as the individual’s name, images, email address, telephone number, bank account details, financial information, professional qualifications, drivers’ license details, details of working with children checks, browser session and geo-location data, additional personal information that is provided directly or indirectly, and any other information requested by us and/or provided by Subscribers and Users.
Icosian handles Subscriber and User information merely as a data processor and the Subscriber is the data controller. Except as provided in this Policy, Icosian will maintain the confidentiality of Subscriber and User information and will not disclose such information to third parties.
Icosian may collect Personal Information directly from You when You:
- register to use the Service,
- use the Service,
- contact the Icosian support team, and
- visit our Website.
You can always choose not to provide Your Personal Information to Icosian, but it may mean that we are unable to provide You with the Service.
Icosian may receive Personal Information from You about others
Through Your use of the Service, Icosian may also collect information from You about someone else. If You provide Icosian with Personal Information about someone else, You must ensure that You are authorised to disclose that information to Icosian and that, without Icosian taking any further steps required by applicable data protection or privacy laws, Icosian may collect, use and disclose such information for the purposes described in this Policy.
This means that You must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Policy, including the fact that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, Icosian’s identity, and how to contact Icosian.
Where requested to do so by Icosian, You must also assist Icosian with any requests by the individual to access or update the Personal Information You have collected from them and entered into the Service.
Icosian may collect sensitive information
Sensitive information is a sub-set of Personal Information that is given a higher level of protection under the Australian Privacy Principles. “Sensitive Information” is information that relates to Your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices and criminal records, health information or biometric information.
The types of Sensitive Information that we may collect or receive include health information, membership of a professional or trade association or trade union, religious beliefs or affiliations, information on philosophical beliefs, information on sexual orientation or practices and information regarding your criminal record, including police checks if applicable. We only collect solicited Sensitive Information if it is reasonably necessary for or directly related to the Service and you have consented to its collection, or its collection is permitted or otherwise authorised by law.
Icosian collects, holds, and uses Your Personal Information for limited purposes
Icosian collects Your Personal Information so that we can provide You with the Service and any related services You may request. In doing so, Icosian may use the Personal Information we have collected from You for purposes related to the Services including to:
- verify Your identity,
- administer the Service,
- notify You of new or changed services offered in relation to the Service,
- carry out marketing or training relating to the Service,
- assist with the resolution of technical support issues or other issues relating to the Service,
- comply with laws and regulations in applicable jurisdictions, and
- communicate with You.
By using the Service, You consent to Your Personal Information and/or Sensitive Information being collected, held and used in this way and for any other use You authorise. Icosian will only use Your Personal Information for the purposes described in this Policy or with Your express permission.
It is Your responsibility to keep Your password to the Service safe. You should notify us as soon as possible if You become aware of any misuse of Your password, and immediately change your password within the Service or via the “Forgotten Password” process.
Icosian can aggregate Your non-personally identifiable data
By using the Service, You agree that Icosian can access, aggregate and use non-personally identifiable data Icosian has collected from You. This data will in no way identify You or any other individual.
Icosian may use this aggregated non-personally identifiable data to:
- assist us to better understand how our customers are using the Service,
- provide our customers with further information regarding the uses and benefits of the Service,
- enhance small business productivity, including by creating useful business insights from that aggregated data and allowing You to benchmark Your business’ performance against that aggregated data, and
- otherwise to improve the Service.
Icosian holds your Personal Information on servers located in Australia
We use top tier, third party data hosting providers’ (Amazon Web Services, Inc) to host our Services on servers located in the Australia. If you are a non-Australian resident, this means that your Personal Information will be transferred to Australia.
By entering Personal Information into the Services, you consent to that Personal Information being hosted on servers located in Australia. While your Personal Information will be stored on servers located in Australia, it will remain within Icosian’s effective control at all times. Each data hosting provider’s role is limited to providing a hosting and storage service to Icosian, and we’ve taken steps to ensure that our data hosting providers do not have access to, and use the necessary level of protection for, Your Personal Information. They do not control, and are not permitted to access or use your Personal Information, except for the limited purpose of storing the information.
Icosian takes steps to protect your Personal Information
Icosian is committed to protecting the security of Your Personal Information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your Personal Information is stored on secure servers that have SSL Certificates issued by Amazon Web Services, Inc.
However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that Your information will be secure at all times. Transmission of Personal Information over the Internet is at Your own risk and You should only enter, or instruct the entering of, Personal Information to the Service within a secure environment.
We will advise You at the first reasonable opportunity upon discovering or being advised of a security breach where Your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.
Icosian only discloses Your Personal Information in limited circumstances
Icosian will only disclose the Personal Information You have provided to us to entities outside the Icosian group of companies if it is necessary and appropriate to facilitate the purpose for which Your Personal Information was collected pursuant to this Policy, including the provision of the Service.
Icosian will not otherwise disclose Your Personal Information to a third party unless You have provided Your express consent. However, You should be aware that Icosian may be required to disclose Your Personal Information without Your consent in order to comply with any court orders, subpoenas, or other legal process or investigation, if such disclosure is required by law. Where possible and appropriate, we will notify You if we are required by law to disclose Your Personal Information.
Icosian does not store Your credit card details
You may request access to Your Personal Information
It is Your responsibility to ensure that the Personal Information You provide to us is accurate, complete and up-to-date. You may request access to the information we hold about You, or request that we update or correct any Personal Information we hold about You, by setting out Your request in writing and sending it to us at email@example.com.
Icosian will process Your request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet Your request, we will let you know why. For example, it may be necessary for us to deny Your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for us to process Your request in the manner You have requested. In some circumstances, it may be necessary for us to seek to arrange access to Your Personal Information through a mutually agreed intermediary (for example, the relevant Subscriber).
We’ll only keep Your Personal Information for as long as we require it for the purposes of providing You with the Service. However, we may also be required to keep some of Your Personal Information for specified periods of time, for example under certain laws relating to corporations, money laundering, and financial reporting legislation.
In providing the Service, Icosian utilises “cookies”. A cookie is a small text file that is stored on Your computer for record-keeping purposes. A cookie does not identify You personally or contain any other information about You but it does identify Your computer.
We and some of our affiliates and third-party service providers may use a combination of “persistent cookies” (cookies that remain on Your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when You close Your browser) on the Website to, for example, track overall site usage, and track and report on Your use and interaction with ad impressions and ad services.
You can set your browser to notify You when You receive a cookie so that You will have an opportunity to either accept or reject it in each instance. However, You should note that refusing cookies may have a negative impact on the functionality and usability of the Website.
We do not respond to or honour “Do Not Track” requests at this time.
You can opt-out of any email communications
Icosian sends billing information, product information, Service updates and Service notifications to You via email. Our emails will contain clear and obvious instructions describing how You can choose to be removed from any mailing list not essential to the Service. Icosian will remove You at Your request.
You are responsible for transfer of Your data to third-party applications
Icosian has a privacy complaints process
If You wish to complain about how we have handled Your Personal Information, please provide our Privacy Officer with full details of Your complaint and any supporting documentation:
Our Privacy Officer will endeavour to:
- provide an initial response to Your query or complaint within 10 business days, and
- investigate and attempt to resolve Your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.
This policy may be updated from time to time
Icosian reserves the right to change this Policy at any time, and any amended Policy is effective upon posting to this Website. Icosian will make every effort to communicate any significant changes to You via email or notification via the Service. Your continued use of the Service will be deemed acceptance of any amended Policy.
Last updated: 14 August 2018