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We take our obligations very seriously and have implemented practices, procedures and systems to ensure we comply with applicable laws. We are committed to maintaining the confidentiality and security of your personal information and managing it in an open and transparent way.
What is Personal Information
For the purposes of this policy, “personal information” is information relating to an identified natural person or an individual who is reasonably identifiable. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data or an online identifier, amongst other things.
We do not consider personal information to include information that has been anonymised or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
Information we collect
We collect personal information from you and from other sources when you use our services. If you do not provide us with the information we request or if we cannot collect this information from other sources, we may not be able to provide you with our services.
In the process of providing our services, the most common types of personal information we collect includes your full name, company name, telephone number, email address, other contact details, payment information such as payment agent, transactional details, web analytics, and usernames.
Wherever it is lawful and practical, you have the option of using a pseudonym or not identifying yourself when dealing with us. However, by doing so you acknowledge that it may affect our ability to provide our products and services to you.
How we collect personal information
We collect personal information directly from you when you provide it to us, automatically as you navigate through the Website, or through other suppliers when you use services associated with the Website.
You will provide personal information to us when you complete registration, buy services, subscribe to a newsletter or email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Your sensitive personal information
Some personal information (e.g. ethnicity, religion, political opinions) is sensitive and requires a higher level of protection under applicable laws. We will only collect your sensitive information when we have your consent; the collection is reasonably necessary for us to carry out one or more of our functions or activities; or is required or authorised by law.
Personal information we collect about you from others
Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular, other third-party sources and or partners located in the United Kingdom, Australia, New Zealand and USA whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data, and combine it with information we have about you. We also receive information about you and your activities on and off the CaterXpress platform through partnerships, or about your experiences and interactions from our partner ad networks.
Dealing with unsolicited personal information
If we receive your personal information from a third party without having asked you for it, then within a reasonable time, we will determine whether we could have collected it in the ways outlined above. If we determine that it could not have been collected in one of those ways and it is lawful and reasonable to do so, then as soon as practicable we will destroy the information; or ensure that it is de-identified.
Use and disclosure of personal information
We will only use and hold your personal information:
(i) for the purpose of conducting our business, to fulfil a contract, or take steps linked to a contract, in particular, providing the services, and facilitating and processing requests and transactions that take place on our Website.
(iii) where this is necessary for purposes which are in our, third parties, and other parties’ legitimate interests. These interests are:
– operating the Website, and providing you with the services described on the Website;
– updating you with operational news and information about our Website and services e.g. to notify you about changes to our Website, any disruptions to the Website, or security updates;
– helping to facilitate the resolution of any disputes;
– carrying out technical analysis to determine how to improve the Website, and the services we provide;
– managing our relationship with you e.g. responding to any comments or queries submitted to us on the Website; asking for your feedback; or whether you want to participate in a survey;
– monitoring activity on the Website e.g. to ensure compliance with any terms that apply to the Website and to identify any potential fraudulent activity;
– to manage our legal and operational affairs;
– training CaterXpress staff on how best to assist our users; and
– providing general administrative and performance functions and activities.
(iv) for purposes which are required by law, if we reasonably believe it is necessary to respond to requests to law enforcement authorities conducting an investigation or by government.
We will only disclose your personal information to the following recipients:
(a) our respective company representatives;
(b) service providers and subcontractors who assist us in connection with the ways we use personal information as set out above, in particular: web hosting providers located in Australia and the USA; technical support located Australia and the USA; communications, marketing and analytics services which are located in Australia and the USA; security and fraud prevention services which are located in Australia and the USA. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations;
(c) our professional advisers (lawyers, accountants, financial advisers etc.) which are located in the Australia and the USA;
(d) regulators and government authorities in connection with our compliance procedures and obligations;
(e) a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase; and
(f) other recipients where we are authorised or required by law to do so.
Marketing regarding your personal information
How we use your personal information for direct marketing is controlled by applicable laws. We will follow those laws to ensure you only receive direct marketing in circumstances where you are expecting to.
We will use your personal information for the purposes of direct marketing where we have your consent to do so. We will send you marketing communications about products and services that we deem are of interest to you.
If at any time you want to know who provided us with your personal information, then please send a request to us at firstname.lastname@example.org. We will provide the details of that third party within a reasonable time and without charge.
We will always provide a simple means for you to “opt-out” from receiving direct marketing, which typically involves an “opt-out” or “unsubscribe” link on emails, or through a pop-up on your screen when you provide personal information online. Alternatively, if at any time in the future you do not want us to send you direct marketing material or you wish to cancel a previous consent, please inform us by contacting us at email@example.com. We will affect the change without charge.
We will not use or disclose your personal information for the purposes of direct marketing if you have previously told us not to.
Cross-border disclosure of personal information
CaterXpress does business in a number of countries and jurisdictions around the world, including (amongst others) Australia, New Zealand, United Kingdom and the USA. Some of the recipients we have described above and to whom we disclose your personal information is done so on the basis of your consent; is required; or as authorised by law.
Security of personal information
We will take such steps as are reasonable in the circumstances to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
We store personal information on secure servers that are managed by us and our service providers. Personal information that we store or transmit is subject to security and access controls, including username and password authentication and data encryption where appropriate.
Your rights concerning personal information
We will take such steps as are reasonable in the circumstances to ensure that your personal information that we collect, use or disclose is accurate, up-to-date, complete and relevant. You have the right to make a request to access your personal information to request corrections of any errors in that data. You may also close the account you have with us at any time.
You are entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you or another data controller), to erase it, or restrict its processing. You also have the right to object to some processing that is based on legitimate interests, such as profiling that we perform for the purposes of direct marketing and where we have asked for your consent to process your data, to withdraw this consent as described below.
Your rights are limited in some situations – for example, if we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we can retain data even if you withdraw your consent.
Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory. If such data is not provided, then we will not be able to manage our contractual relationship with you, or meet obligations placed on us.
If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country:
(i) of your habitual residence;
(ii) of your place of work; or
(iii) in which you consider the alleged infringement has occurred.
Retention of personal information
CaterXpress takes steps to ensure that it retains personal information for as long as is necessary to fulfil the purposes described in this policy, deal with disputes and comply with our legal obligations. When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to ensure that the information is de-identified.
Our Policies Concerning Children
CaterXpress does not knowingly collect any personal information from children. If any party becomes aware that a child under the age of 16 has provided us with personal information in contravention of our policies, they should contact us at firstname.lastname@example.org.
How our customers manage their data