In Australia, we act in a manner that is consistent with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). For individuals located within the European Union, we comply with the General Data Protection Regulation (EU) 2016/679 (GDPR).
What personal information do we collect?
When you register as a user of our app or visit our website we may collect the following types of personal information from you:
your email address and telephone number;
the city and country in which you live;
metrics including your gender, date of birth and age;
your device ID, device type, geo-location information (including the country that you reside in based on this), computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
information you provide to us through customer surveys; or
any other personal information that may be required in order to facilitate your dealings with us.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
register on our website or app, or when someone provides your contact details to us so that we may invite you to register on our website or app;
communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
interact with our sites, services, content and advertising;
supply us with products or services or apply to work with us; or
donate to our business or enquire as to a potential investment in our business.
Personal information relating to employees, applicants and contractors
In addition, when you apply for a job or position with us we may collect certain personal information from you (including your name, contact details, working history and relevant records checks) as part of the application process. We may also collect these types of information about you from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.
Why do we collect, use and disclose personal information?
We will collect, hold, use, process and disclose your personal information for the purposes set out in the table below. If you are located within the European Union, the lawful basis for our collection, holding, use, processing and disclosure of your personal information is also set out in this table.
|Purpose of processing||Lawful basis|
|To operate, protect, improve and optimise our mobile application and services business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing||For our legitimate interests in operating our business efficiently and effectively|
|To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you||Your consent (if given to us)
|To send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our supporters that we think you may find interesting||Your consent (if given to us)|
|To comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties||Compliance with our legal obligations
For our legitimate interests in enforcing our contractual and legal rights
We may also disclose your personal information to a trusted third party who also holds other information about you (such as Apple or Facebook, for example). This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the service and experience that you receive through the app.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about our app and upcoming events that you might be interested in attending. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).
To whom do we disclose your personal information?
- our employees, volunteers and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of our websites and app and/or our business or in connection with providing our products and services to you);
- professional advisers, dealers and agents; and
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of Australian personal information outside Australia
We may disclose personal information outside of Australia to:
third parties such as Apple, Amazon Web Services, MixPanel, Work in Progress and Priya that are located outside of, or may store personal information outside of, Australia including but not limited to the United States of America, Romania and India;
app developers and testers located in Romania and India; and
our employees and to our volunteers in other countries including Romania, the United Kingdom, Germany, Bulgaria, India, Finland, the United States of America and the Netherlands.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Transfers of personal information of European individuals outside of the European Union
We may disclose personal information to:
- our employees and to our volunteers located in countries outside of the European Union, including India and the United States of America;
- third parties such as Apple, Amazon Web Services, MixPanel, Work in Progress and Priya that are located outside of, or may store personal information outside of, the European Union, including but not limited to the United States of America, Australia and India; and
- app developers and testers that are located outside of, or may store personal information outside of, the European Union, including in India.
When we disclose personal information in this manner, we do so:
on the basis of an adequacy decision under Article 45(9) of the GDPR in respect of the EU-US Privacy Shield Framework for any US-based third party who has self-certified its compliance with the EU-US Privacy Shield Framework to the US Department of Commerce; or
otherwise on the basis of a data transfer agreement with that third party that implements standard data protection clauses as permitted under Article 46.2 of the GDPR (details of the relevant safeguard can be obtained upon request by sending an email to firstname.lastname@example.org).
Using our website and cookies
We may collect personal information about you when you use and access our website and app.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website and app, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use 'cookies' or other similar tracking technologies on our website and app that help us track your website and app usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, we cannot guarantee the security of your personal information.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the contact information provided through the website or using the contact details set out below . Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us using the details set out below and we will take reasonable steps to ensure that it is corrected.
Additional rights under GDPR for individuals within the European Union
If you are located within the European Union, then you also have the following additional rights under the GDPR. We will comply with all of our obligations under the GDPR in respect of these rights.
Where we process any personal information about you on the basis of any consent given by you, you have the right to withdraw your consent at any time by giving notice to us (which you can do using our contact details set out above). We will give effect to your withdrawal of consent promptly and will cease any processing that you no longer consent to, unless we have another lawful basis for that processing. The withdrawal of your consent will not affect the lawfulness of any processing that occurred prior to the date that you notified us that you were withdrawing your consent.
You have a right to information portability, which is the right in certain circumstances to request a copy of your personal information in in a structured, commonly used and machine-readable format and to transmit this information to another data controller. You may also request that we erase any personal information that we hold about you which is no longer necessary for any of the purposes that we collected it for, which you have withdrawn your consent in respect of or processing which you are allowed under the GDPR to object to. We will comply with such requests unless we are permitted or required by law to retain that information.
You also have the right to object to our processing of personal information in certain circumstances, including where we process personal information based on our legitimate interests. You can also request that we restrict our processing activities in some circumstances. If you make such a request in those circumstances, then we will continue to store your personal information but will not otherwise process your personal information without your consent or as otherwise permitted by law.
Making a complaint
If you wish to make a complaint about the way we have handled your personal information (including if you think we have breached the GDPR if you are located within the European Union), or you wish to make a complaint about the way we have handled your personal information, you can contact us through our website at www.thedarwinchallenge.org by sending a message through our Contact Us link or by using the contact details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
For the purposes of the GDPR, our representative within the European Union is Cosmin Bălaj of 2 Emil Isac, Apartment 9A, Cluj-Napoca, 400023, Cluj, Romania.
As our core activities do not consist of processing operations that require regular and systematic monitoring of data subjects on a large scale, we are not required under GDPR to appoint a data protection officer.
- by post at Level 4, Deutsche Bank Place, 126 Phillip St, Sydney NSW 2000, Australia;
- by email at email@example.com; or
- via our website at www.thedarwinchallenge.org by sending a message through our Contact Us link.
Effective: 25 May 2018