This Privacy Policy sets out how we collect, use, disclose, store and protect your Personal Information. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously.
In this Privacy Policy we, us or our means Sekuro (Sekuro Operations Pty Ltd, ABN 52 652 187 785) and its subsidiaries.
1. Collection
1.1 What Personal Information do we collect?
Personal Information includes information or an opinion (whether true or not) about an individual that is identified or reasonably identifiable.
The type of Personal Information we collect may include:
- Contact information (e.g. name, email address, postal address, company information, and other profile information),
- Login details,
- Comments,
- Preferences,
- Feedback,
- User data (see ‘What types of cookies do we use?’ section below), and
- Any other Personal Information that may be required to facilitate your dealings with us.
We do not currently collect financial information, such as your payment method, for any services.
Sekuro does not intentionally collect personal information from children. Individuals over 16 years old can consent to the processing of personal information; anyone younger than 16 requires the consent of their parent or guardian.
1.2 How do we treat Personal Information that is also Sensitive Information?
Sensitive Information includes information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We will collect sensitive information only where relevant and with your consent (e.g. if you register for an event, we may ask you for information about your health, any disabilities or special dietary needs, or we may collect such information if we need it to provide you with our professional advice).
1.3 Why do we collect Personal Information?
We collect Personal Information for purposes connected with our activities and operations, including:
- To enable you to access and use our website, associated applications and associated social media platforms,
- To contact and communicate with you,
- For internal record keeping and administrative purposes,
- For analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms,
- To run competitions and/or offer additional benefits to you,
- For advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you,
- To meet our legal obligations and resolve any disputes that we may have,
- To consider your employment application, and
- To understand and meet the needs and requests of individuals.
2. Use and Disclosure
2.1 How might Sekuro use and disclose your Personal Information?
Sekuro may use and disclose your Personal Information for the purposes described in this Privacy Policy, or for related purposes which would reasonably be expected by you, or for purposes to which you have consented, and in circumstances otherwise required or authorised by law.
We may disclose your Personal Information to:
- Our employees, contractors and/or related entities,
- Our existing or potential agents or business partners,
- Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred,
- Third parties, including agents or subcontractors, who assist us in providing information, products, or services. This may include parties located, or that store data, outside of Australia. including in the European Union, United Kingdom of Great Britain and Ireland (UK), Singapore, the Philippines, and Malaysia,
- Third parties to collect and process data. This may include parties that store data outside of Australia, including in the United States, Singapore and United Kingdom,
- Credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you,
- Sponsors or promoters of any competition we run,
- Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise or defend our legal rights, and
- Third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, webhosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators.
2.2 Do we use your Personal Information for direct marketing?
We may send you direct marketing communications and information about our services. You may opt out of receiving marketing materials from us by contacting us using the details set out below for the Data Protection and Privacy Officer or, if it is an email, by using opt-out facilities such as an unsubscribe link.
2.3 Sending information overseas
We may share your information among companies affiliated directly with Sekuro. This may involve sending your personal information to these offices overseas.
We may also disclose your information to:
- Our service providers, agents and contractors from time to time that provide services to us and/or help us to provide and market our services to you,
- Specific third parties authorised by you to receive information held by us, and
- Other persons, including government agencies, regulatory bodies and law enforcement agencies, or as otherwise required or authorised by law.
Some of these vendors or other parties may receive or store your information in overseas locations. For example, we may disclose your email address or other contact information to providers of electronic execution services, which may store the information in an overseas jurisdiction.
Our service providers are located around the world. The countries in which recipients are likely to be located include Australia, the United Kingdom, Malaysia, the Philippines, and Singapore.
European Union and United Kingdom of Great Britain and Ireland (UK)
Sekuro adheres to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (GDPR), for individuals within the EU. For individuals within the UK, Sekuro adheres to the GDPR as set out in the Data Protection Act 2018.
If you are located in the EU or UK, we will only transfer your personal data to another country if:
- We have implemented appropriate safeguards to govern the transfer (most commonly through standard contractual clauses), or
- The country that your personal data is being transferred to has been deemed to have adequate data protection measures in place by the relevant authorities within the EU or UK.
2.4 How long do we retain your Personal Information?
We retain Personal Information about you for as long as necessary to provide you with our services, or until we receive a request to delete it. In some cases, we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable laws. Afterwards, we occasionally retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.
2.5 What types of cookies do we use?
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology. For further information, please visit our cookie page.
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features might not function as a result.
2.6 Privacy policies of other websites
The Sekuro website also contains links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their Privacy Policy before using their website.
3. Storage and Security
3.1 How do we store your information, and how do we keep it secure?
We are committed to ensuring that the Personal Information we collect is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
As part of its information security, cybersecurity, and privacy protections, Sekuro maintains certification to ISO 27001:2022.
However, we cannot guarantee the security of your Personal Information. If you do use the internet to send us any information, including your email address, please be aware that it will be at your own risk.
4. Your rights and options we provide for controlling your Personal Information
Choice and consent: Please read this Privacy Policy carefully. By providing Personal Information to us, you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us. You do not have to provide Personal Information to us, however, if you do not, it may affect your use of this website, or the products and/or services offered on or through it.
Access: You may request details of the Personal Information that we hold about you. We may charge you a small fee for this service. If so, we will inform you of the fee before processing your request. In certain circumstances (for example, including those set out in Australia’s Privacy Act 1988 (Cth), we may refuse to provide you with Personal Information that we hold about you.
Erasure: You have the right to request that Sekuro erase your personal data, under certain conditions.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Information from third parties: If we receive Personal Information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Information to us.
Restrict processing: You have the right to restrict processing of your personal information, under certain conditions. If we receive Personal Information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Information to us.
Object to processing: You have the right to object to Sekuro’s processing of your personal data, under certain conditions.
Data portability: You have the right to request that Sekuro transfer the data we have collected to another organisation, or directly to you, under certain conditions.
5. Contacting us and making a complaint
5.1 How to contact us
If you have any questions about Sekuro’s Privacy Policy, the information we hold on you, or you would like to exercise one of your information protection rights, please contact us.
Contact: Data Protection & Privacy Officer
Email: [email protected]
Phone: +61 1800 735 876
Address:
L5, 727 George Street, Sydney, 2000, NSW, Australia (for global matters)
5.2 How to make a complaint
If you think we have breached any relevant local legislation, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint.
Any complaint will be investigated by the firm’s Directors and the outcome of that investigation communicated to you (please allow at least 30 days for us to do so).
Australia
You can make a complaint at any time with the Office of the Australian Information Commissioner (OAIC) at [email protected] or on 1300 363 992. More information is available on the OAIC’s website at https://www.oaic.gov.au/.
European Union and United Kingdom of Great Britain and Ireland (UK)
You have the right to make a complaint at any time with the relevant national Data Protection Authority (list of relevant authorities available here).
For the UK, you have the right to make a complaint at any time with the Information Commissioner’s Office here.
Singapore
You have the right to make a complaint at any time with Singapore’s Personal Data Protection Commission here.
Updates to this Policy
We may update this Policy from time to time by publishing it on our website. We recommend you check our website regularly to ensure you are aware of our current terms. Materials and information on this website are subject to change without notice. We do not undertake to keep our website up to date and we are not liable if any content is inaccurate or out-of-date.