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IT Global — Privacy Policy
IT GLOBAL PTY LTD (ABN 26 160 457 205) and its affiliated companies, including INCLOODME PTY LIMITED (ABN 26 631 887 459) (we, us and our) is committed to protecting the privacy of your personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).
 
We understand that you trust us with your personal information and we are committed to keeping that trust.
 
Please take a moment to read this privacy policy (Privacy Policy) as it explains how we collect, use, disclose and hold your 'personal information' (that is, information or an opinion about you, whether true or not, which identifies you or from which your identity is reasonably identifiable) and how to contact us if you have any queries about our management of your personal information.
 
This Privacy Policy also contains information about how you may access you personal information, seek correction of your personal information and make complaints if you think we have breached any privacy laws and how we will deal with such complaints.
 
  1. How we collect personal information
     
    1. We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.  Where it is reasonably practical to do so, we will collect your personal information directly from you.  We may collect your personal information in a variety of ways, including:
       
      1. when you interact with us in writing, electronically or by telephone;
         
      2. when you access, use or interact with one of our products or services (including our portals and applications) (Community Suite) (for example, if you post or upload information to the Community Suite, make a phone call, send an email or message, request a job, task or quote or submit a contact form, banking details, details of addresses and items you own or compliance information);
         
      3. through your use of the Community Suite, and any associated applications and third party systems which interface with the Community Suite;
         
      4. through our other members' and users' (including your employer, employees, social or professional networks, friends, families, clubs, associations, customers, suppliers, or individuals employed by your educational institution) use of the Community Suite (including when those members or users post on any community forums or message boards), and any associated applications and third party systems which interface with the Community Suite;
         
      5. from publically available sources and other third parties, such as members' and other users' of the Community Suite, our associated entities, related & non related authorities, law enforcement agencies, emergency services, government bodies and agencies, insurers, suppliers, recruitment agencies, referees, banks, contractors, sales representatives, social media, clubs and associations commercial data lists and our other clients and business partners;
         
      6. when you enter competitions or subscribe to our email or mobile services and newsletters;
         
      7. when you provide us with information in response to direct marketing or customer satisfaction and market research surveys and questionnaires;
         
      8. in the course of administering or providing any of our products or services, including the Community Suite;
         
      9. in the course of administering, performing or managing contracts with our service providers or other third parties;
         
      10. when you apply for employment with us; and
         
      11. as otherwise required to manage our business.
         
  2. The kinds of personal information we collect and hold
     
    1. The kinds of personal information we collect and hold about you will depend on a range of circumstances, including who you are and which services and products you are looking to access or use.
       
    2. Generally, the personal information we collect can include (but is not limited to):
       
      1. your name, date of birth, age, gender, postcode and other demographic information;
         
      2. your contact details, such as your email, postal and work addresses and phone numbers;
         
      3. information to verify your identify, such as your driver's licence or passport details, photos or signatures;
         
      4. billing and financial information (such as your banking or payment information, credit card number, cardholder name and expiration date);
         
      5. information about properties, assets or other items the subject of requests for work or services through the Community Suite or otherwise recorded by you using the functionality of Community Suite, including details about when those items were recorded, serviced, stored, their conditions and location;
         
      6. if applicable, employment information, such as job application information;
      7. information relating to incidents relating to our business or the products or services we provide, such as personal injuries, misconduct, breach of conditions, unlawful activity, claims or disputes;
         
      8. any information which is publicly available, including on a third party social media service; and
         
      9. any other information or photos you provide us from time to time, including photos of you, your preferences or opinions relating to the products and services we provide, and information relating to surveys, competitions, enquiries or complaints.
         
    3. In addition, when you register for, or access or use, the Community Suite or other products or services we provide:
       
      1. (Account Information) we may collect your account login details, company and personal details, contact information, financial and billing information and any other information you provide when you register an account with us;
         
      2. (Usage data) we may collect and log usage data about how you interact with the Community Suite and our services, such as access dates and times, features used, content or advertisements viewed, crashes and other system activity, referring websites, searches performed, content shared or transactions engaged in;
         
      3. (Non-identifiable information) we may collect non-identifiable information about your hardware, software and activities, which can include your IP address, browser type, domain names, pages you accessed and the dates and times you accessed them, how long you spent on those pages and our website, and referring website addresses (including through the use of 'cookies' as described in section 3 below);
         
      4. (Transactional Information) we may collect details of transactions, tasks or activities which you initiate or participate in, or perform, when using the Community Suite (including through associated applications and third party supported systems), including details of sites, assets, the type of services requested or provided, order details, the date and time on which services were provided, the amount charged and the payment method;
         
      5. (Compliance and Warranty Information) we may collect compliance information, such as details of licenses and accreditations, works and warranty documentation; insurances, government security checks, police checks, criminal record checks, working with children checks and other background checks, associations and authorisations;
         
      6. (Profile) we may collect information that you submit to us regarding your online profile within the Community Suite, such as your education, work experience, skills, photograph, location and endorsements;
         
      7. (Posting) we may collect any information that our members and users provide when they post to a community forum or message board, or otherwise upload to the Community Suite, such as forms, responses to surveys, resumes or reviews;
         
      8. (Synced Address book and calendar information) if you opt to import or sync your address book or calendar (where permitted by the Community Suite), we may collect information about your contacts within that address book and calendar meeting information;
         
      9. (Content provided by others) we may collect information provided by our members and other users of the Community Suite that includes information about you, including information provided on our community hubs and as part of articles, posts, comments, feedback, referrals and ratings;
         
      10. (Public information) we may collect public information about you, such as professional-related news and accomplishments (for example, professional recognition, conference speakers, projects, etc.);
         
      11. (Contact information provided by others) we may collect information (including contact information) about you when others import or sync their address book or calendar with the Community Suite, associate their contacts with member profiles, or send messages using the Community Suite (including invites or 'Inclood' connection requests);
         
      12. (Device information) we may collect information about the system or device which you use to access the Community Suite, websites or other products or services we provide, including the type of system or device, its name, MAC address, location and movement data, operating system, browser type, software, IP address, data usage and other information relating to that system or device;
         
      13. (Location tracking and data) if you use the Community Suite from a mobile device which has location tracking enabled, or you have linked a vehicle or other asset that has location tracking enabled with your member account, and you have opted in to location tracking with us, we may collect geo-location and movement data from that device, vehicle or asset, including location verification data, the dates and times that the device, vehicle or asset was at a location and how long it stayed at that location (ie time on site).  We will ask you to opt-in before we use GPS or other location tracking tools to identify your precise location or the location of linked vehicles and assets;
         
      14. (Workplace information) we may collect your personal information from others purchasing access to the Community Suite for your benefit, such as your employer, including information about your eligibility to use the Community Suite on their behalf; and
         
      15. (Communications information) we may collect personal information contained in any communications made between our members and other users in relation to the Community Suite, including your availability to be contacted by members, calls, video and conferencing, emails, messaging, SMS and internal tasking, private and community adds and blogs, and other information relating to those communications, such as the source, date, time and duration of the communication.
         
    4. In some circumstances, we may collect sensitive information about you where permitted by law. Sensitive information includes (for example) health information and information about a person's racial or ethnic origin, political opinions, religious beliefs, professional or trade association membership, sexual preferences and criminal record.  Examples of sensitive information we may collect about you include:
       
      1. details of licenses and accreditations;
         
      2. government security checks, police checks, working with children checks; and
      3. details of professional associations and memberships.
         
    5. We will not collect sensitive information about you unless you have consented to the collection (including by contributing content through one of the products or services we provide, such as by entering the data when using the Community Suite), or we are otherwise required or authorised to do so by or under the law of any jurisdiction.
       
  3. Cookies
     
    1. Our Community Suite and websites may use 'cookies' as part of their interaction with your computer or device.  A 'cookie' is a small text file placed on your computer or device for a pre-defined period of time by our server for later retrieval.  Cookies are frequently used by businesses and you can choose if and how a cookie will be accepted by configuring your preferences and options in your computer or device.  Cookies do not alter the operation of your computer or device in any way.
       
    2. In some cases, cookies and other tools we use on the Community Suite and websites record information in a way that does not personally identify you as an individual. In other cases, information may be personal information, in which case this Privacy Policy will apply. For example, we will collect personal information if you are a member of the Community Suite or when you follow us through our social media websites, or when you post comments or communicate on or through the public areas of the Community Suite, our website or social media websites.
       
    3. We may use cookies to identify specific machines and website interactions in order to collect aggregate information on how visitors are experiencing the Community Suite and our websites.  This information will help to better adapt the Community Suite and our websites to suit our members and users' requirements.
       
  4. The purposes for which we collect, hold, use and disclose personal information
     
    1. We collect and use personal information about you primarily to supply you with the Community Suite and any other the products and services you order from us and our related companies.
       
    2. As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances.  In particular, we collect, hold, use and disclose personal information for a range of purposes, including:
       
      1. to communicate with you (including by phone, email, text message, SMS, MMS, push notifications, notices, alerts and social media);
         
      2. to supply products and services (including the Community Suite) to our members and users, including to provide members and users with all of the functionality available through the Community Suite, and to request feedback about those products and services and the Community Suite;
         
      3. to allocate potential jobs, tasks, roles, responsibilities and authorities to appropriate members;
         
      4. where you have opted in to location tracking for a mobile device, vehicle or other asset, to track the dates and times that the device, vehicle or asset was at a location and how long it stayed at that location, to provide an indicator as to your availability to perform jobs and to monitor your safety and security;
         
      5. to verify your identity and create, maintain and administer your member account;
         
      6. to associate your member account with a particular email address;
         
      7. to provide personalised content, functionality and accessibility options relating to the products and services we provide;
         
      8. to assist you to stay in touch and keep up to date with colleagues, partners, clients, and other professional contacts through the Community Suite (including by facilitating communications and notifications through the Community Suite);
         
      9. to share information that you include in your profile or concerning certain activities you undertake on the Community Suite (where permitted by the functionality within the Community Suite, and subject to any options permitted to be selected by you when using that functionality);
         
      10. to facilitate 'Inclood' connections between you and other members and users of the Community Suite (including using information provided as a result of members and users importing or syncing their address book or calendar) and to enable you to invite others to become a member or user of the Community Suite (note that when you invite someone to 'Inclood' connect with you, that invitation will include your name, photo, network and contact information);
         
      11. to help you to stay informed about news, events and ideas regarding professional topics or potential work, career, training or educational opportunities and other information we believe may be relevant to you (some of which may be accessible through the Community Suite) based on the personal information you submit to us and activities you perform through the Community Suite;
         
      12. to help you to collaborate with colleagues and search for, and 'Inclood' connect with, potential clients, customers, partners and others to do business with;
         
      13. to record and process your orders and communicate with you about those orders;
         
      14. to process and validate payments relating to the Community Suite and other products and services;
         
      15. to invite you to participate in a survey or customer research and, if you choose to participate, to register and administer your participation;
         
      16. to manage and administer the Community Suite and other products and services we provide (including the performance of those products and services), and otherwise to appropriately manage and conduct our business, including providing training and performing administrative functions such as billing and accounts and records management;
         
      17. to provide you with customer service or technical support (including follow-up or ongoing support), and deal with any complaints or feedback you have;
         
      18. in relation to the management and security of the Community Suite and our products and services, including to assess, monitor, log and action security and other incidents relating to use of the products and services we provide (such as potentially fraudulent, illegal, unsafe or improper usage of the Community Suite or activities that contravene the Terms of Use to which the Community Suite are subject), which may involve disclosure of personal information to law enforcement agencies, emergency services, government bodies and insurers;
         
      19. to manage our relationships with our suppliers and contractors;
         
      20. to consider job applicants for current and future employment;
         
      21. in relation to legal proceedings or claims or disputes relating to the Community Suite or other products or services;
         
      22. to comply with our legal and regulatory obligations and to facilitate contractual compliance, personal and community safety;
         
      23. to conduct research and development and for the purposes of business planning, including the further development of the Community Suite and other products and services;
         
      24. to create aggregated non-identifiable data (including location data) about our members and users and share that data with third parties so that they can to serve advertisements to our members and users on the products and services we provide (including the Community Suite);
         
      25. otherwise for direct marketing purposes, including to prepare and provide marketing information about the products and services we provide and those of our related companies and other organisations, work, career, training or educational opportunities we believe may be relevant to you, and other information in accordance with the privacy laws and sections 6, 7 and 8 below;
         
      26. as part of community resource libraries made available to our members and other users, where you elect to do so;
         
      27. to facilitate an acquisition or divestiture or all or part of our business;
         
      28. for any purpose disclosed to you and to which you have consented; and
         
      29. for any purpose that you would otherwise reasonably expect.
         
    3. We may use and disclose your information for other purposes required or authorised by or under the law of any jurisdiction (including purposes for which you have provided your consent).
       
    4. If we are unable to collect personal information from or about you:
       
      1. we may not be able to respond to your requests or enquiries;
         
      2. you may not be able to use the Community Suite or other products or services we provide (or use them to their full extent), including where jobs, products or services require you to opt-in to location tracking for your vehicle or mobile device; or
         
      3. we may not be able to do business with you or the organisation with which you are related.
         
  5. Our community and providing information about other individuals
     
    1. Certain personal information about you will be visible to all members of the Community Suite as part of your member profile. At a minimum, this information will include your name, photo, age, availability to be contacted, contact details, times and locations where you can perform work, profession or job description, your Inclood network connections, referrals and Inclood Community Ratings. You can manage the personal information that is visible to other members as part of your member profile in your member account settings, however this may limit the ability of other members to identify and 'Inclood' connect with you.
       
    2. Please note that additional information may need to be disclosed to other members in order to accept jobs or tasks through the Community Suite.  For example, you may need to disclose certain compliance information about you so that the person requesting the job or task can ensure that you hold the necessary licenses and accreditations to perform that job or task.
       
    3. The Community Suite allows members to view and share information with other community members on public or group forums, including through posts, likes, follows, comments and sharing or linking comments, content and members. When you engage in these social interactions certain personal information about you may become visible to, and searchable by, other members or group members.  Members may also be notified when other members visit their profile, including details from the visiting member's public profile.
       
    4. Through the Community Suite, you may gain access to the personal information of another member or user.  You must protect this personal information and only use it for the legitimate purposes in relation to your use of the Community Suite.
       
    5. In addition, you must not disclose the personal information of another individual to us unless you have first obtained that individual’s consent to you providing their personal information to us on the terms of this Privacy Policy. This includes where you are a registered member acting on behalf of another individual.
       
  6. Direct marketing and customer surveys
     
    1. Like most businesses, marketing is important to our continued success. We therefore like to stay in touch with customers and let them know about new opportunities.
       
    2. From time to time we may contact you to market our products and services and those of selected third parties to you, including, special offers, promotions and other events that may be of interest to you.  We may also invite you to participate in surveys or customer research on a range of issues, including satisfaction with the products and services we provide. These surveys help us to improve those products and services and tailor the way we do business with you.
       
    3. We may contact you by email, SMS, MMS, mail, social media or telephone. You may opt-out at any time from receiving communications from us that are not account related or legally required by contacting us using the contact details at the end of this Privacy Policy or using the opt-out/unsubscribe facility in our communications.
       
  7. Advertising through the Community Suite
     
    1. We may serve you tailored advertisements and marketing communications from time to time when you use the Community Suite (for example, based on your trade or the jobs you typically quote for on the Community Suite, places you like to shop or other general things of interest you share on the Community Suite).  Where required by law, we will provide an op-out/unsubscribe facility for these advertisements and communications as contemplated in section 6.3.
       
    2. We target (and measure the performance of) such advertisements and marketing communications either directly or through a variety of partners. Generally we may use the following information (whether separately or combined) in relation to our advertising activities through the Community Suite:
       
      1. data from advertising technologies utilised as part of our services, like web beacons, pixels, ad tags, cookies, and device identifiers;
         
      2. information provided to us by our members and users of the Community Suite (for example, profile information, contact information, title and industry information);
         
      3. data from your use of the Community Suite (for example search history, content you gain access to, your 'Inclood' connections, community rating, participation in discussions, posts, advertisements you click on);
         
      4. information and keywords associated with job or task requests;
         
      5. information from advertising partners and publishers; and
         
      6. information inferred or generated from data described above (for example, using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender).
         
    3. We may show you advertisements which are labelled as "sponsored".  If you take an action (such as like, comment or share) in relation to these advertisements, that action is associated with your name and viewable by our members and other users of the Community Suite, including the advertiser.
       
  8. Disclosure of personal information to third party advertisers
     
    1. From time to time we may disclose your personal information to third parties for the marketing and advertising purposes. We do not share your personal data with any third-party advertisers or advertising networks for their advertising except for:
       
      1. hashed or device identifiers (to the extent they are personal information);
      2. with your separate permission; or
         
      3. data already visible to our members and users of the Community Suite (for example your member profile).
         
    2. However, if you view or click on an advertisement on or off our Community Suite, the advertising provider will get a signal that someone visited the page that displayed the advertisement, and they may collect personal information about you through the use of mechanisms such as cookies.
       
  9. Disclosure of personal information to third parties
     
    1. In addition to any specific disclosures referred to above, we may disclose your personal information for the purposes outlined above to third parties including:
       
      1. our members, customers or other users of the products or services we provide, including the Community Suite, for example, if you use the Community Suite or those products or services on their behalf or transact with them using the Community Suite or those products or services;
         
      2. our related companies, agents and organisations;
         
      3. entities seeking to acquire all or part of our business;
         
      4. companies or institutions that your account is associated with (for example, your employer or educational institution);
         
      5. our suppliers, partners insurers and contracted service providers, including:
         
        1. information technology service providers;
           
        2. communications carriers and exchange providers;
           
        3. marketing, promotional and market research agencies;
           
        4. data analytics providers;
           
        5. research partners, including those performing surveys or research projects in partnership with us or on our behalf.
           
        6. background check providers;
           
        7. service providers that assist us to enhance the safety and security of the Community Suite; and
           
        8. external business advisors or consultants (such as auditors and lawyers);
           
      6. if you are a job applicant, referees whose details you have provided to us; and
         
      7. other third parties with your consent.
         
    2. We may also disclose your personal information to other third parties and for other purposes where we are required or authorised by or under law to do so (including where you have provided your consent).  For example, to law enforcement agencies, emergency services and government bodies.
       
  10. Disclosure of personal information to overseas recipients
     
    1. Some of our service providers are located overseas and, as a result, we may disclose personal information collected and held by us overseas where permitted by law.
       
    2. In particular, we use developers located in Australia, Brazil, China, India and Mexico and our servers are hosted by Amazon Web Services primarily in Australia, but also in other countries where Amazon may host their servers from time to time. Some of our service providers may also share information with their headquarters located in the United States.
       
    3. If in future we do propose to disclose personal information to other overseas recipients, we will do so in compliance with the requirements of the privacy laws.  We will, where practicable, advise you of the countries in which any overseas recipients are likely to be located.
       
    4. Other users of the Community Suite may be located outside of Australia and not subject to the Privacy Act 1998 (Cth). If you have uploaded, posted or transmitted personal information for sharing with other users, and if we (rather than you) are regarded as disclosing this personal information to another user who is an overseas recipient, you consent to us disclosing such personal information to such other user. By providing this consent you are aware that if the overseas recipient handles the personal information in breach of the Australian Privacy Principles, we will not be accountable under the Privacy Act 1998 (Cth) and you will not be able to seek redress under the Privacy Act 1998 (Cth).
       
  11. How we hold personal information, and quality and security of personal information
     
    1. We may hold personal information as either secure physical records, electronically on our intranet system, in cloud storage or on third party servers.  In particularly we currently use third party servers hosted by Amazon Web Services. Details of the security measures and systems in place for those services are available at https://aws.amazon.com/security/.
       
    2. We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, interference, unauthorised access, disclosure, or modification of personal information, including when we dispose of personal information.
       
    3. We further protect personal information by restricting access to personal information to only those who need access to the personal information to do their job.  Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.
       
    4. We encourage you to review the security settings in your account at your earlier convenience.
       
  12. Access to, and correction of, your personal information
     
    1. In some cases you will be able to access and correct the personal information we hold about you through your member account settings. In other cases, please contact us (using the contact details at the end of this Privacy Policy) if you would like to access or correct the personal information we hold about you and provide us with as much detail as possible to enable us to best assist with your request. We will respond within a reasonable period of time, but we may need further information to verify your identity.
       
    2. We will generally provide you with access to your personal information (subject to some exceptions permitted by law), but may charge an access fee to cover the cost of retrieving the information and supplying it to you. If we deny any request by you to access or correct your personal information, we will provide our reasons for doing so. Where we decide not to make a requested correction to your personal information and you disagree, you can ask us to make a note of your requested correction alongside the information.
       
  13. Account deletion and information retention
     
    1. You may request deletion of your account at any time through the privacy settings in your account settings in the Community Suite.  Following such a request, we will delete information relating to your account where possible and provided that it is no longer needed for a valid purpose or required to be kept by law. We will not be able to delete information that has been provided to other members and users of the Community Suite (including by you) or that you have disclosed in relation to a public forum or social interaction in relation to the Community Suite.
       
    2. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute between us and you, or between us and another member or user of the Community Suite to which the information pertains. Upon resolution of the issue preventing deletion, we will delete your account as described above.
       
    3. We may also retain certain information if necessary for our legitimate business reasons as indicated in this Privacy Policy, such as fraud prevention. For example, if we shut down a member account because of unsafe behaviour or security incidents, we may retain certain information about that account to prevent that member from opening a new account in the future.
       
  14. Complaints
     
    1. Please contact us (using the contact details at the end of this Privacy Policy) if you have any concerns or complaints about this Privacy Policy or the manner in which we have collected or handled your personal information (including under the APPs or other binding codes).
       
    2. We take all complaints seriously and will inquire into your complaint and respond to you in writing within a reasonable period.  If you are not satisfied with the handling of your complaint, you can contact us to discuss your concerns or lodge a complaint with the Australian Information Commissioner (www.oaic.gov.au).
       
  15. Changes to this Privacy Policy
     
    1. We may amend this Privacy Policy from time to time at our discretion.  An up-to-date copy of our Privacy Policy is available at our offices at Level 1 52 Whiting Street, Artarmon NSW 2065 Australia, at our website https://www.itglobal-systems.com/a-quest-to-connect-people-assets or on request.
       
    2. This Privacy Policy was last updated on 28 February 2019.
       
  16. Contact details and additional information
     
    1. If you would like more information about our approach to privacy, or if you wish to contact us regarding the information set out in this Privacy Policy, please contact our privacy officer:
       
      1. by phone: 1300 IT GLOBAL
         
      2. by email:   info@itglobal-systems.com
         
      3. by post:    1,52 Whiting Street, Artarmon, NSW 2064, Australia
         
    2. Nothing in this Privacy Policy is intended to limit our ability to rely on any exemptions under the Privacy Act 1988 (Cth).