Privacy Policy

1. Overview

Prrickly (“Prrickly”, “we”, “us”, “our” or “ours”) is committed to protecting the privacy of your personal information in accordance with Australian privacy laws. 

Our Privacy Policy sets out how we and our related entities collect, use, disclose and manage your personal information. 

Our Privacy Policy complies with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) as amended from time to time (‘Privacy Act’). 

2. Information collection and processing

In the course of using our Website, we ask you to provide us with certain personal information. The personal information that we collect, process and file is:
(A) Your contact information; e.g. your full name, company name, email address, postal address and phone number.
(B) Information regarding the use of our services and information related to tasks and projects (for example, budget, location, timing or feedback).

We use Stripe, a third party payment processor for payment collection and processing. They may also collect and process personal information, such as Credit Card information. We encourage you to read the privacy policies or statements of these services.

Please note that any feedback you provide will be publicly viewable.

When you visit our Website, our servers automatically record information that your browser sends whenever you visit a website. This log data may include information such as your computer’s Internet Protocol, IP address, browser type, browser software version or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics.
In addition to this, we may use third party services (for example, Google Analytics or Google Tag Manager) that collect, monitor and analyse this type of information with the purpose of increasing our Website’s functionality and user-friendliness, to better tailor it to our visitors’ needs, and in some cases to detect suspicious activity. These third party service providers have their own privacy policies addressing how they use such information. We use cookies to record this information. See our cookie policy below.

3. Our cookie policy

3.1 Cookies we collect

Like many websites, we also use “cookies” to collect information. A cookie is a string of information that a website stores on your computer, and that your browser provides to the website each time you return to the website. It is for record-keeping purposes.
We utilise session ID cookies to enable certain features of our Website, to better understand how you interact with the Website and to monitor aggregate usage by users and web traffic routing on the Website.
Session cookies are deleted from your computer when you close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
If you do not accept cookies, however, you may not be able to use all portions of the Website or all functionality. When you visit our Website, our servers automatically record information that your browser sends whenever you visit a website. We use the cookies to collect log data.

3.2 Third party cookies

We use third party services to analyse the use of our site for statistical purposes. We may also use advertising-related cookie to understand the performance of our advertising activity.
 

4. Use of personal information

We use your personal information to provide the Service, complete your transactions, and administer your enquiries. We only use your personal information to contact you with our newsletters, marketing or promotional materials if you have given us your prior consent or if it is otherwise permitted under applicable law. If you decide at any time that you no longer wish to receive such communications from us, please use the subscription management options provided in any of the communications to manage your preferences, or unsubscribe completely. We may also use general information from your use of our Services for statistical analysis and product development.

5. Cross border disclosure

Your personal information may also be processed by, or disclosed to employees, representatives, or other third parties operating outside of Australia who work for, or are engaged by us in other countries. For example, we may use a server hosted overseas to store data, which may include your personal information.
We will take reasonable steps, in the circumstances, before your personal information is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach privacy laws in relation to your personal information (“the reasonable steps”). 
The reasonable steps may not apply if you consent to the disclosure of your personal information to an overseas recipient and we reasonably believe that the overseas receipt is subject to laws that are suitability similar to privacy laws in Australia.  
If you consent to the disclosure of your personal information to an overseas recipient, the overseas recipient may not be accountable under the Privacy Act and you will not be able to seek redress for breaches under the Privacy Act. 

6. Specific rights of European residents

We are committed to ensuring our compliance with the European Union General Data Protection Regulation (“GDPR”). 
Although our Privacy Policy explains how we meet all of its obligations for Australian individuals, we may also have some individuals who are habitually located in the European Union (“EU Residents”) that have additional rights in respect of their Personal Data.

Personal Data is defined as: “Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.  This should be considered fundamentally interchangeable with the Australian expression “Personal Information” for the purposes of this Privacy Policy.

Under the GDPR, Prrickly is primarily a “controller” of Personal Data, as opposed to being a “processor”.

As part of its GDPR compliance, we provide our Services in a way that ensures:

Personal Data (i.e. Personal Information) is:
(A) processed fairly, lawfully and in a transparent manner; and
(B) collected and processed only for specified and lawful purposes.
 
Processed Personal Data (for example, Personal Information that is used, held or disclosed by Prrickly) is:
(C) adequate, relevant and not excessive;
(D) accurate and, where necessary, kept up to date;
(E) kept secure, and not longer than necessary;
(F) not transferred to countries outside the European Union without adequate protection; and
(G) treated in accordance with individuals’ legal rights.

Whilst we strive to provide all individuals with appropriate access and control over their data, individuals covered by the GDPR are also able to:
(H) prescriptively restrict, limit or otherwise provide instructions to us regarding how we can use their Personal Data. This includes being able to object to how and why their Personal Data is used (for example, by the removal of their consent for particular functions);
(I) request the erasure (for example, deletion) of their information; and
(J) request that we provide all Personal Data held about them in a portable format, meaning in a way that is structured, commonly used and machine-readable. Individuals who exercise this right to data portability are also able to direct us to transmit this data to other entities who they intend to allow to process their Personal Data.

We will allow and assist individuals that are EU Residents to exercise these rights, unless we have compelling and legitimate legal grounds not to (for example, a legal obligation under Australian legislation, or if the Personal Data has been fully anonymised).

7. Information we collect

7.1 Collecting sensitive information

We do not collect sensitive information, unless it is specifically relevant and necessary for the purpose of our business activities and functions, and your consent is first obtained. In such cases, all sensitive information that is collected is used in accordance with this privacy policy.

7.2 Government identifiers

We do not use government identifiers (for example, tax file numbers, or Medicare numbers) to identify individuals.

8. Disclosure

8.1 Aggregate information and non-identifying information

We may share aggregated information that does not include personal information and we may disclose non-identifying information with third parties for industry analysis, demographic profiling and other purposes.

8.2 Compliance with laws and law enforcement

We will only disclose information about you to government or law enforcement officials or private parties if we are obliged to do it, for example due to a legal obligation, or believe it is necessary in order to pursue our legitimate interests, such as responding to claims and legal process, protecting the property and rights of ours or a third party, protecting the safety of the public or any person, or preventing or stopping activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

8.3 Storage of your personal data

Your personal data will be stored as long as necessary for the purposes above which, as a main rule, would be as long as there is an ongoing Client relationship. Any further retention may take place for documentation purposes.
 

9. Your data protection rights

You have the right of access to information relating to you. You also have the right to request rectification and under certain circumstances deletion of incorrect or misleading information that we have registered about you. Further, you have the right to restriction of processing of your personal data and the right to object. Under certain circumstances, you may also a have a right to data portability. If you have consented to processing of your personal data, you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing prior to withdrawal. Please contact us in writing by emailing yann (at) prrickly.com if you wish to exercise any of these rights.
 

10. Security

We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security. 
If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable. 
We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if we no longer need to retain it. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored. 

11. Links to other sites

Our Website contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
 

12. Changes in the Privacy Policy

We may at any time and without notice make changes to its Privacy Policy with future effect.
 

13. Transfer of ownership

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, your Personal Information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of our business (or its assets) will continue to have the right to use your Personal Information in accordance with the terms of this Privacy Policy.
 

14. Complaints and disputes

If you have reason to believe that we have not complied with our obligations relating to your personal information under this Privacy Policy or under the Privacy Act, please refer any compliant to queries to our Privacy Officer, Yann Ott at yann (at) prrickly.com. 
We will ensure your compliant is handled in an appropriate and reasonable manner and is responded to in a reasonable timeframe.  Were necessary we may consult with our related entities and partners in order to deal with your complaint. A written notice of our decision regarding your complaint will be provided to you. If you are not satisfied with the outcome, then you may contact the Office of the Australian Information Commissioner // www.oaic.gov.au // 1300 363 992.

Our Privacy Policy was last updated on 11. November 2023

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