The App is owned and operated by Sweeney Interpreting Pty Ltd, ABN 14 605 245 609 (‘Sweeney Interpreting’, ‘We’, ‘Us’ or ‘Our’).
YOUR PRIVACY IS IMPORTANT TO US
We are committed to protecting Your Personal Information. This Privacy Policy details how We handle Your Personal Information and how we comply with the Privacy Act, including the Privacy Principles.
This Privacy Policy explains how We collect, use, store and disclose Personal Information, how You can access, correct and update Your Personal Information and how You can contact Us about Our privacy practices.
Please read this Privacy Policy carefully, it forms part of and should be read in conjunction with Our Terms and Conditions. Note, this Privacy Policy only relates to the App and does not cover Personal Information We collect, use, store and disclose in other interactions relating to the conduct of Our business, including (without limitation) Our recruitment process or when We engage with contractors.
If You have any questions, You can contact Us using the details in the CONTACT section below.
DEFINITIONS
In this Privacy Policy, the following capitalised terms have the meanings:
‘App’ means the Sweeney Interpreting App, being Our mobile app on iOS and Android and any other app We may own or operate from time to time;
‘Personal Information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, as defined in the Privacy Act;
‘Privacy Act’ means the Privacy Act 1988 (Cth);
‘Privacy Policy’ means Our privacy policy only for the App;
‘Privacy Principles’ means the Australian Privacy Principles contained in the Privacy Act; ‘Sensitive Information’ means information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, or health, genetic or biometric information; ‘Terms and Conditions’ means Our App Terms and Conditions; and
‘You’ or ‘Your’ means the App user.
OVERVIEW
We comply with the Privacy Act and the Privacy Principles. The Privacy Principles govern standards, rights and responsibilities in relation to the collection, use and disclosure of Personal Information, an organisation’s governance and accountability, the integrity and correction of Personal Information, and the rights of individuals to access their Personal Information.
This Privacy Policy outlines Our approach to privacy and how We endeavour to protect Your Personal Information. It describes how We collect, use, store and disclose Your Personal Information and Your rights to access the Personal Information We collect and store about You, and how You can contact Us about Our privacy practices.
When You submit Personal Information to Us and/or register an account on the App to use, view, access or otherwise browse any of the services, resources, benefits, features, functions, technologies or content offered by Sweeney Interpreting, You indicate that you have read, understood and accept this Privacy Policy and You agree to abide by it. You also consent to the collection, use, storage and disclosure of Personal Information as outlined in this Privacy Policy. You do not have to consent to Us collecting, using, storing and disclosing Personal Information, however if You do not agree with this Privacy Policy in its entirety, We will not be able to provide You with the services, resources, benefits, features, functions, technologies or content You have requested and You will not be able to use the App.
WHAT PERSONAL INFORMATION WE COLLECT
We collect Personal Information when You submit Personal Information to Us and/or register an account on the App. Personal Information We collect may include:
▪ First name, last name and preferred name;
▪ Email address;
▪ Account login credentials, password and details relating to Your unique user identity question (this is encrypted so no-one can read it);
▪ Postal address;
▪ Telephone number;
▪ Profile picture;
▪ IP address;
▪ Account settings;
▪ National Disability Insurance Scheme (‘NDIS’) information;
▪ Employment Assistance Fund (‘EAF’) information;
▪ Billing information;
▪ Financial information, including credit/debit card details; and/or
▪ Any other information You supply to Us.
Payment transactions may be processed by Our third-party service provider, Stripe Payments Australia Pty Ltd (‘Stripe’). Stripe collects and stores credit or debit card details in accordance with their terms of use and privacy policy. Where Stripe is used to process Your payment, You consent to Stripe processing Your online payment transaction and to Stripe’s privacy policy.
We may collect Sensitive Information in accordance with the Privacy Act, but only if You agree to provide it to Us.
You may provide Us with, and we may collect from You, Personal Information relating to a third-party, including when You provide Personal Information about Your employees. In such cases, it is Your responsibility to ensure those individuals are aware of, read, understand and accept this Privacy Policy and consent to the collection, use, disclosure, sharing and storage of their Personal Information as outlined in this Privacy Policy. You represent to Us that You have obtained the consent of the third-party to provide Us with their Personal Information for the respective purposes.
We may collect information about Your use and interaction with the App to protect You from fraudulent activities and to prevent Personal Information being exploited. Accordingly, We may collect technical information from Your computer, mobile, tablet or other device/technology to identify any malicious, fraudulent, illegitimate or illegal activities.
When you use the App, You will generate information that we can view, including timestamps, edited information that will override previous information, and interactions with Our team. We may also collect and use aggregated data (e.g. demographic data) for statistical analysis.
HOW WE COLLECT PERSONAL INFORMATION
We collect Personal Information from You using lawful and fair means. Personal Information We collect from you directly, includes when You:
▪ Register an account on the App;
▪ View, access, browse or use any of the services, resources, benefits, features, functions, technologies or content offered on the App;
▪ Submit Personal Information on the App;
▪ Sign up to Our marketing communications on the App;
▪ Participate in a competition or promotion, which is conducted by us directly or through a third-party service provider through the App;
▪ Interact with Us or contact Us through the App;
▪ Participate in a survey or submit feedback on the App;
▪ Enter a competition or promotion on the App; and/or
▪ Voluntarily submit Personal Information to Us for any reason.
We may obtain Personal Information about You from third-parties, related companies, credit reporting bodies, identity verification services and publicly or commercially available sources, for the purpose of complying with applicable laws.
You may elect to give us access to Personal Information stored by third-party websites, such as social media sites. You may also allow for social media integration, such as login to Your App account using Your social media login credentials. Personal Information We receive in such manner is controlled by the third-party website and varies from site to site. By linking a third-party website with Your App account, You authorise Us to have access to this information and consent to the collection, use and disclosure of this Personal Information as detailed in this Privacy Policy.
PURPOSES WE COLLECT, USE, STORE AND DISCLOSE PERSONAL INFORMATION
We collect, use, store and disclose Personal Information for the purposes it was collected, and related purposes. We do not buy or sell Personal Information. Purposes we may collect, use, store and disclose Personal Information include to:
▪ Set up Your account on the App;
▪ Provide You with access to relevant parts of the App;
▪ Identify customers and provide You with the services, resources, benefits, features, functions, technologies or content You have requested;
▪ Provide customer support;
▪ Monitor and improve Our services, resources, benefits, features, functions, technologies or content;
▪ Communicate with You regarding Our services, resources, benefits, features, functions, technologies or content;
▪ Send You newsletters, information and deliver targeted marketing communications about Our services and those of Our third-party service providers, including direct marketing;
▪ Inform You of competitions, promotions, offers or additional benefits;
▪ Invite You to participate in Our events or surveys;
▪ Conduct market research;
▪ Market and promote Our business, services, resources, benefits, features, functions, technologies or content. If You submit comment on the App about Our business, services, resources, benefits, features, functions, technologies or content, You consent for Us to use Your comments on the App and any other marketing collateral, in which We will identify You by your first name only;
▪ Notify You of service, security, privacy and other updates relating to the App;
▪ Send push notifications on Your mobile device;
▪ Carry out accounting, billing and administrative functions;
▪ Resolve disputes and troubleshoot problems on the App;
▪ Manage, support, improve or develop Our business;
▪ Undertake statistical and analytical functions;
▪ Confirm Your identity for the purposes of applicable laws and to assess Your suitability for the services, resources, benefits, features, functions, technologies or content You have requested;
▪ Monitor, measure and improve satisfaction of Our services and those of Our third-party service providers;
▪ Measure activity, improve and develop the App;
▪ Facilitate the process involved in enabling a sale or merger, if Sweeney Interpreting is sold to or merges with another company;
▪ Conduct fraud monitoring, detection and prevention activities;
▪ Satisfy Our legal and regulatory obligations, including with our third-party service providers and suppliers;
▪ Protect Our lawful interests, investigate and prevent potentially illegal activities;
▪ Comply with applicable laws; and/or
▪ Pursue Our legitimate business interests and as is reasonably necessary in the conduct of Our business.
HOW WE STORE AND PROTECT PERSONAL INFORMATION
We store Personal Information in electronic form on our internal database, which is held on our online server, as well as in hard copy, physical form.
Where Our third-party service provider Stripe is used to process Your payment transaction, credit or debit card details are securely stored and protected by Stripe. Stripe’s security measures can be found on their webpage and the way in which Stripe stores and protects Personal Information can be found in Stripe’s privacy policy.
Personal Information is subject to access controls. Our authorised administrator users have full access to Personal Information. All Our other employees, Our third-party service providers and employees of Our third-party service providers have restricted access to Personal Information, limited to a need-to-know basis depending on the function or job they perform and the services they provide to You.
We may combine or link Personal Information we already hold about You to other Personal Information We collect about You.
We take reasonable physical, technical and administrative safeguards to store Your Personal Information safely and protect it from misuse, interference, loss, unauthorised access, modification or disclosure. Examples include: all access to our online server is encrypted in transmission by electronic security technologies such as Secure Sockets Layer (SSL); monitoring Our employees access to Personal Information; and auditing our third-party service providers and their employees to ensure their access to Personal Information is limited to a need-to-know basis depending on the function or job they perform.
When You register an account on the App and create Your account login credentials, password and details relating to Your unique user identity question to access the App, You are responsible for keeping this Personal Information secure. You should select a strong password, avoid a generic user identity question and You should not share this information with any other party.
We retain your Personal Information if we are providing You with services, resources, benefits, features, functions, technologies or content You have requested. We may retain your Personal Information after We cease providing You with Our services, resources, benefits, features, functions, technologies or content for the purposes of complying with legal, taxation, accounting and financial reporting requirements and for monitoring, detecting and preventing fraudulent or illegal activities. We retain data in line with limitation periods and obligations required by applicable laws. If Your Personal Information is no longer required, We take reasonable steps to ensure it is not compromised. In such circumstances, We securely destroy or permanently de-identify your Personal Information, unless We are required to retain the information under applicable laws.
No data transmission or storage system is guaranteed as entirely secure. Irrespective of Our reasonable precautions to protect Your Personal Information, We cannot take responsibility or guarantee the security of any Personal Information You send to Us, or receive from Us. We are not liable for any misuse, interference, loss, unauthorised access, modification or disclosure of Personal Information. Any Personal Information You transmit to Us is at Your own risk.
HOW WE DISCLOSE PERSONAL INFORMATION AND TO WHO
We will only disclose Personal Information for the purposes outlined in this Privacy Policy, or as otherwise notified to You at the time of collection.
We may share Personal Information with:
▪ Our related companies, employees and contractors;
▪ Vendors and other third-party service providers, suppliers and professional advisors (including their employees) who assist in the conduct of Our business, such as development, support or hosting of the App, credit reporting, fraud prevention, identity verification, marketing and promotion, market research, statistics and analytics, customer service, debt recovery, legal, accounting, auditing, business consulting or technology services, for example NDIA, ClickSend, Twilio, Amazon Web Services, Asana, Mailchimp and Xero;
▪ Providers of third-party programs or platforms, such as Apple;
▪ Our online payment processor, Stripe. The manner in which Stripe discloses Personal Information can be found in Stripe’s privacy policy;
▪ Banking institutions;
▪ A party intending to acquire, invest or merge with Us; and/or
▪ Other parties where You have provided Your express consent or direction.
We will disclose Personal Information to law enforcement, government authorities or other third-parties, as authorised by applicable laws or in circumstances permitted by the Privacy Act. For example: in response to a subpoena, court order, or other legal obligation; where We have reasonable grounds to suspect unlawful activity or misconduct of a serious nature is being, or may be engaged in; or where We reasonably believe that disclosure is necessary to prevent fraudulent or illegal activities relating to Our services, resources, benefits, features, functions, technologies or content.
DISCLOSURE OF PERSONAL INFORMATION OVERSEAS We may disclose Personal Information to recipients located outside of Australia. This may occur in the following instances:
▪ When the App or online server is hosted overseas;
▪ Where Personal Information is disclosed to Our related companies, directors, representatives, employees or consultants located overseas;
▪ When Personal Information is shared with a third-party described above, including Our third-party service providers located overseas.
While it is not practicable for Us to specify in advance each country where Personal Information may be transferred, stored or processed, countries may include the United States. The data protection and privacy laws in these countries may be different. You hereby consent to the transfer of Personal Information to recipients outside of Australia.
COOKIES
We use cookies to improve and personalise Your experience on the App and provide You with a better service. Cookies are an industry standard and used by most websites. Cookies make Your online experience more user-friendly by allowing Our web applications to customise their operations to You. Cookies store information about Your preferences and do not personally identify You as the user.
We may use cookies to save Your password so You don’t need to re-enter it each time You access the App. We may also use cookies to collect statistical information relating to Your use of the App, which include: Your IP address; your geolocation; the date and time You access the App; pages You have accessed; how You were referred to each page and time spent on each page; Your carrier/operating system; and Your browser type.
Most web browsers are set up to automatically accept cookies. Cookies can be managed by accessing the settings in Your browser. You can set Your browser to refuse cookies, unless cookies are needed to safeguard the App or to prevent fraudulent activities. However, if You refuse cookies You may be prevented from taking full advantage of the App and We may not be able to provide You with the services, resources, benefits, features, functions, technologies or content You have requested.
By visiting, browsing, accessing, registering an account on the App or using the services, resources, benefits, features, functions, technologies or content offered on the App and agreeing to this Privacy Policy, You consent to Us placing and storing cookies on Your browser for the purposes outlined in this Privacy Policy.
FACEBOOK ANALYTICS TOOLS
We may use analytics tools to help Us track Your interaction on Our Facebook page, allowing Us to track usage and improve page performance. Third-parties, including Facebook, may use cookies, web beacons or tracking pixels and other storage technologies to collect or receive information from the App and elsewhere on the Internet and use that information to provide measurement services and target ads. You should refer to Facebook’s privacy policy. You may opt-out of the collection and use of information for ad targeting by clicking here.
EXTERNAL SITES
The App may include links to external websites. These external websites are not in Our control and are not subject to this Privacy Policy or Our Terms and Conditions. We are not responsible for Personal Information You may provide whilst visiting external websites. We strongly recommend that you make your own enquiries as to the privacy policy and terms of external websites.
The App may link to social media sites. If You choose to ‘like’ or ‘share’ information from the App through social media sites, You should review the privacy policy of those sites. If You have an account with a social media site, that site may link Your visits to the App with Personal Information.
MARKETING COMMUNICATIONS
We may send you marketing communications, including direct marketing by telephone, email messaging, push notifications on your mobile device, mobile messaging (SMS/MMS), mail or any other forms of contact You supply to Us. You may opt-out of receiving marketing communications by notifying us using the details in the CONTACT section below or by clicking the unsubscribe link in marketing communications. You can also manage your marketing preferences or disable marketing options at any time by logging into Your account on the App. You can further manage Your push notification preferences or deactivate them using the settings feature on your mobile device.
ACCESSING, CORRECTING AND UPDATING PERSONAL INFORMATION
You can contact Us to access, correct or update Personal Information We hold about You.
If you request access to Personal Information, We will endeavour to make it available to You within 30 days, unless giving access is unlawful or We are subject to restrictions or We are required to process Your request earlier under applicable laws.
It is important Your Personal Information is accurate and current. Please keep us informed if Your Personal Information changes. We will take reasonable steps to ensure Personal Information We collect, use, store and disclose is correct, up-to-date and complete.
If You request to correct or update Personal Information, We will correct, update, or if We consider it more appropriate, note your request for amendment of Personal Information on Your record.
You can access, correct or update Personal Information by using the details in the CONTACT section below or by logging into Your account on the App and updating details.
You can delete Your App account by logging into Your account and requesting its deletion. We will process Your request within a reasonable timeframe from receiving Your notice withdrawing Your consent.
To access, correct or update Personal Information or to delete Your account on the App, We require You to verify your identity. We may also need more information as to why the information We have is inaccurate or incomplete.
COMPLAINTS
If You have a complaint about the way We handle Your Personal Information, You can contact us using the details in the CONTACT section below. We will consider Your complaint and take all reasonable steps to remedy any issues. We will endeavour to respond to you within 30 days. If You are not satisfied with the outcome of your complaint, you may seek a review by contacting the Office of the Australian Information Commissioner.
YOUR RIGHTS
Your rights include:
▪ You have the right to access Personal Information We have about you;
▪ You have the right to ask how We use Your Personal Information, and We must tell you;
▪ You have the right to make amendments to Personal Information We have about you;
▪ You have the right to ask for Your Personal Information to be deleted;
▪ You have the right to withdraw consent that You may have previously given Us.
In order to exercise Your rights, We will require You to verify Your identity.
CONTACT
For any questions or enquiries about this Privacy Policy, or the way We handle Personal Information, or if You would like to access, correct or update Personal Information, or if You have a complaint, please contact Us on the details below, marked for the attention of the Privacy Officer:
▪ By Post: PO Box 251, Vincentia NSW 2540
▪ By Email: chevoy@sweeneyinterpreting.com.au
GOVERNING LAW
This Privacy Policy and Your use of the App is governed in all respects by the laws of New South Wales, Australia.
UPDATES TO THIS PRIVACY POLICY
We reserve the right to alter, amend, modify or otherwise update this Privacy Policy in our sole and absolute discretion from time to time, without notice to You. Updates will be effective immediately upon publication on the App and replace any prior Privacy Policy published by Us to date. When we do so, it will be made available on this page and will indicate the date of the latest revision. Please check this page for further updates. By continuing to use the App after publication of any updates, You acknowledge and agree that you have read, understood and accept to be bound by this Privacy Policy as altered, amended, modified or otherwise updated.
Last Update: 8 November 2022