DOGIT PRIVACY POLICY
1. Introduction
(a) Our mobile application (DOGIT App) and the Products and the Services made available through the DOGIT App are created and controlled by DOGIT Pty Ltd (DOGIT, our, us or we).
(b) DOGIT are committed to ensuring your Personal Information is protected. DOGIT manages your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
(c) By accessing and using the DOGIT App, Products and Services and/or purchasing Products through the DOGIT App you agree to this Privacy Policy.
(d) This Privacy Policy outlines how DOGIT collects, stores, processes, shares, uses and discloses your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
(e) For the purpose of this Privacy Policy:
(i) Services means the dog training and education lessons, materials and instructional videos and online forum made available through the DOGIT App; and
(ii) Products means pet accessories and products made available for purchase through the DOGIT App.
2. The information DOGIT collects about you 2.1. Personal Information
(a) Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.
(b) DOGIT collects and uses Personal Information and Non-Personal Information from users of the DOGIT App and Services, purchasers of Products offered by us through the DOGIT App from time to time, and any other individual who interacts with us.
(c) DOGIT will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, make the DOGIT App available to you and deliver our Products and Services to you, or as otherwise permitted by law.
(d) The type of Personal Information and Non-Personal Information that DOGIT collects and uses depends on the type of dealings that you have with DOGIT and includes the following:
(i) contact details and account registration information (for example, full name, email address, username and password [and anything else?]);
(ii) information relating to your dog(s) (for example, your dog’s breed, age, and [insert]);
(iii) any photographs or images published or posted by you on, or via, the DOGIT App (such as images of you and/or your dogs);
(iv) marketing data and information relating to your dealings, or enquiries you have made, with us, including information about: (i) the Products and/or Services you have orders, purchased or used; and (ii) the third party products and services you have used or enquired about;
(v) payment and billing information;
(vi) device information which is automatically collected from you when you visit and navigate through the DOGIT App and use the Services. Such information may include, but is not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the DOGIT App or Services, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the DOGIT App and other usage statistics; and
(vii) other information that you provide to us or that we may collect in the course of our relationship with you.
2.2. Sensitive Information
(a) We do not collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information.
(b) If you have accidentally sent us Sensitive Information, please contact us using the details below.
3. How DOGIT collects Personal Information 3.1. Direct collection from you
(a) We will collect Personal Information and Non-Personal Information about you in a number of different ways. We may collect Personal Information and Non-Personal Information directly from you or in the course of our dealings with you. For example, when you:
(i) setup and create a profile on the DOGIT App (including when you edit or update your profile on the DOGIT App or reset your password) and when access and use the DOGIT App and Services;
(ii) when you purchase Products on, or via, the DOGIT App (including information about the Products you have ordered or purchased);
(iii) publish or submit information, material or data on, or via, the DOGIT App (for example, your photographs, images, or other information relating to your dog’s characteristics, training and [anything else?]);
(iv) contact or correspond with us online (for example, when you complete online forms, or subscribe to our publications, alerts and newsletters), request customer support services, contact us via email or telephone with a query or request or make a comment on our social media sites or you participate in a promotion, competition or survey; or
(v) from publicly available sources of information.
3.2. Collection from third parties
(a) We may also collect Personal Information about you from publicly available sources and third parties, including:
(i) when you provide your Personal Information to third parties (including to our related bodies corporate, business partners, service providers and third party contractors);
(ii) if you use:
(A) our social media sites or applications; or
(B) other third party products and services that interact with, or connect with, the DOGIT App, the Services and Products (such as third party e-commerce platforms and third party payment processors);
(b) When DOGIT collects your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
(c) If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
(i) inform them that you are providing their Personal Information to us; and
(ii) advise them that they can contact us for further information.
(d) You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including 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 access that information, and who we are and how to contact us.
4. How DOGIT uses your Personal Information 4.1. Purposes of use and disclosure
(a) DOGIT only uses, processes and discloses your Personal Information and Non-Personal Information for the purposes for which it is collected.
(b) In particular, DOGIT uses, processes and discloses your Personal Information to:
(i) provide you with access to, and use of, the DOGIT App and to provide the means through you can access, order and purchase and use Services and/or Products offered, or made available through the DOGIT App;
(ii) manage, operate, maintain, test, develop, improve and upgrade the DOGIT App, systems, Products and Services, or other products and services offered by us from time to time, informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the DOGIT App, the Services and Products;
(iii) notify you of opportunities we think you might be interested in, including new products or services offerings, information about the DOGIT App, Services and Products, offers, competitions, promotions, events and surveys;
(iv) to customise the advertising and content on our DOGIT App;
(v) to verify your identity;
(vi) to conduct fraud, risk reduction and creditworthiness checks;
(vii) to perform research and analysis about the DOGIT App, Services and Services and for data analytics purposes, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your Personal Information for this purpose, we ensure Personal Information is made anonymous by removing data that can identify you;
(viii) charge and bill you to access and use the DOGIT App, Services and Products;
(ix) for direct marketing purposes (see section 6 below);
(x) to comply with regulatory or other legal requirements,
(xi) for any purpose to which you have consented; and
(xii) for any other purpose notified to you at the time of collection.
(c) In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.
4.2. Disclosure to third parties
(a) With your consent, we may provide your Personal Information and Non-Personal Information to the following recipients:
(i) our employees, related entities, business partners, third party contractors, suppliers and agents from time to time for the purpose of delivering, providing and administering the Services (including customer support services), the DOGIT App, our promotions, deals and competitions;
(ii) third party service providers who process or use your Personal Information and Non-Personal Information for the purpose of performing functions on our behalf, but may not process or use such information for any other purpose. Examples of these third-party service providers include, but are not limited to, such as cloud-based accounting software platform; e-commerce platforms (such as [insert]), marketing and analysis organisations, financial and credit card institutions to process payments or and third party payment processors, hosting companies, web developers, internet service providers, customer service providers, customer support specialists, fulfilment companies and research and data analysis firms, government agencies, public registries, search agencies, regulatory and licensing bodies, parties to whom you refer us (for example, previous employers and referees); and
(iii) external business advisors, such as auditors, lawyers, insurers and financiers,
(collectively, Authorised Affiliates).
(b) When we disclose your Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.
(c) Our Authorised Affiliates may also provide us with Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliate, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.
(d) DOGIT may also disclose any Personal Information we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.
4.3. Third party payment processors
We use a third party payment processors to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processors, [insert], whose use of your Personal Information is governed by their privacy policy, which may be viewed at [insert].
4.4. Overseas disclosure
(a) In the course of providing you with access to, and use of, the DOGIT App, Services and Products, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to our third party payment processors located outside of [insert] and elsewhere in the world.
(b) The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, DOGIT will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
(c) By accessing or using the DOGIT App, Products and Services, or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to our overseas Authorised Affiliates. If you do not wish to receive information from any of our Authorised Affiliates, please let us know using the details below. However, if you do not provide your Personal Information to us or our Authorised Affiliates, we may not be able to provide you with access to, and use of, the DOGIT App, Products or Services.
4.5. Disclaimer
(a) DOGIT will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless:
(i) we are otherwise required by the relevant Privacy Act;
(ii) we are permitted to under this Privacy Policy; or
(iii) such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the DOGIT App.
(b) This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.
5. Notifiable Data Breaches Laws
In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, DOGIT will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach laws contained in the Privacy Act.
6. Marketing communications
6.1. Direct marketing
(a) DOGIT may use and disclose your Personal Information to send you information about the DOGIT App, Products and/or Services and any other products or services we may offer from time to time, as well as other information that may be of interest to you.
(b) These communications may continue, even after you stop using the DOGIT App, Products and/or the Services.
6.2. Communication channels
(a) DOGIT may send this information to you via the communication channels
specified at the time you provide your consent.
(b) These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices or advertising on the DOGIT App.
6.3. Opting-out
You can opt out of receiving these communications by:
(a) contacting us using the details below; or
(b) using the unsubscribe function in the email or SMS.
7. Storage and security
7.1. Protecting your Personal Information
(a) We take reasonable steps in the circumstances to keep your Personal Information and Non-Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information. Some of the safeguards that we use include [
appropriate, e.g. firewalls and data encryption, physical access controls to data
insert as
centres, SSL (Secure Socket Layer) encryption when transmitting payment
information, and information access authorisation controls.]
(b) Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.
(c) Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information and Non-Personal Information take reasonable steps to:
(i) protect and maintain the security of your Personal Information and Non-Personal Information; and
(ii) comply with the Australian Privacy Principles when accessing and using your Personal Information.
7.2. No guarantee
(a) The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information and Non-Personal Information, we cannot guarantee the security of any Personal Information and Non-Personal Information transmitted through the DOGIT App.
(b) You provide your Personal Information and Non-Personal Information to us at your own risk, and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information and Non-Personal Information.
7.3. Destruction of Personal Information
We will destroy or de-identify Personal Information where it is no longer required, unless we are required or authorised by law to retain the information. However, DOGIT may retain Personal Information (including basic registration information) in accordance with documentation retention and destruction laws.
8. Accessing and correcting your Personal Information
(a) DOGIT shall use our reasonable endeavours to keep your Personal Information accurate, up-to-date and complete. You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act.
(b) You can access, or request that we correct, your Personal Information by writing to us using the details below. DOGIT may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing.
(c) We will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.
(d) We will endeavour to respond to your request for access or correction within [eg 30 days] from your request.
9. Cookies policy
9.1. Cookies
(a) DOGIT and its Authorised Affiliates may collect information by automated means when you access and use the DOGIT App by utilising features and technologies of your internet browser, including cookies and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.
(b) The type of information we and our Authorised Affiliates collect may include statistical information, details of your operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links which you have clicked and the type of browser that you were using and browser and login authentication status.
(c) We may use cookies and similar technologies to:
(i) enable us to identify you as a return user, make it easier for you to login to the DOGIT App and personalise and enhance your experience and use of the DOGIT App; and
(ii) help us improve our Service to you when you access the DOGIT App and to ensure that the DOGIT App remains easy to use and navigate.
(d) Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or warn you before accepting cookies.
(e) If you reject our cookies or similar technologies, you may still use the DOGIT App but may only have limited functionality of the DOGIT App.
(f) We may also use your IP address to analyse trends, administer the DOGIT App and other websites we operate, track traffic patterns and gather demographic information.
9.2. Google Analytics
(a) Services that our website may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our website. By using our website, you consent to Google processing your data in the manner described in Google’s Privacy Policy (www.policies.google.com/privacy) and for the purposes set out in this Privacy Policy.
(b) Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out (see https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbm efodhfapmkghcbnh/related?hl=en-GB).
10. Privacy complaints
(a) If you have any issues about this Privacy Policy or the way DOGIT handles your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
(b) At all times, privacy complaints:
(i) will be treated seriously;
(ii) will be dealt with promptly;
(iii) will be dealt with in a confidential manner; and
(iv) will not affect your existing obligations or your commercial arrangements with us.
(c) Our Privacy Officer will endeavour to:
(i) respond to you within [eg 10] business days; and
(v) investigate and attempt to resolve your concerns within [eg 30] business days or any longer period necessary and notified to you by our Privacy Officer.
(d) If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner.
11. How to contact us
DOGIT can be contacted by email at customersupport@dogit.com.
'12. Changes to this Privacy Policy
(a) From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the DOGIT App.
(b) We encourage you to check the DOGIT App from time to time to ensure you are familiar with our latest Privacy Policy.