Our privacy commitment
DINGO Software Pty Ltd ABN 20 053 730 331 (“DINGO”, “we” or “us”) recognises the importance of protecting your privacy. We are committed to ensuring the continued integrity and security of the personal information you entrust to us.
What personal information do we collect and hold?
The types of personal information we collect will depend on the circumstances in which the information is collected. However, the types of personal information we collect and hold about you may include:
- identifying information (eg your name and date of birth);
- contact information (eg your address, email address and telephone/mobile number);
- details of any products or services we provide to you and information about how you use those products or services;
- your username and password;
- records of our communications with you (eg telephone, email, SMS, online and in-person communications);
- server log information, such as details of how you used our products or service (including our website), IP address, hardware settings, browser type, browser language, the date and time of your use and referral URL, and real-time location information;
- other information that you provide us during the course of business; and
- other information that may be capable of identifying you.
If you choose not to supply us with this information, we may not be able to allow you to access or use our products or services (or all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.
How do we collect personal information?
We may collect personal information about you in the following ways:
- when you order products or services from us;
- when you visit our offices or we visit your sites or offices;
- when you submit a query or request to us (including in-person and via telephone calls, email and our website);
- when you respond to a survey or feedback request, participate in a competition that we run or fill in forms on our website;
- by tracking your use of our products and services (including our website and mobile applications);
- when you apply for a job with us or are employed by us;
- from publically available sources (including social media platforms (e.g. LinkedIn) which have their own separate privacy policies that govern the access and use of personal information held by those sources;
- from third parties who are entitled to disclose that information to us (including from commercially available third party databases); and
- other lawful means.
Where we collect personal information from you, we will generally do so directly ourselves. However, in some cases we may collect personal information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.
How do we use personal information?
We use personal information that we collect about you to:
- verify your identity when you are dealing with us;
- determine your eligibility for any of our products or services;
- enable us to provide you or your organisation with our products and services;
- assist you with your queries, requests or concerns;
- monitor use of our products and services (including our website);
- maintain and update our records (including in our customer relationship management database);
- keep you informed about our activities and notify you of any changes to our products or services;
- comply with our legal and regulatory obligations, or as otherwise required or authorised by law;
- manage and resolve any legal or commercial complaints or issues;
- perform our necessary business functions (eg employee education and training, internal audit investigations, performance reporting, market research and analysis), and to assess, operate, maintain, secure, upgrade and improve our products and services (including our website); and
- any other purpose as authorised by you.
We may use your personal information for marketing purposes. We may contact you about our products and services (including our website), the products and services of other people, or related special offers from our business partners, that we think may be of interest to you. This information may be sent to you by email, SMS or by other means. You can opt-out of receiving marketing communications from us at any time by following the ‘unsubscribe’ link in the communication or contacting us using the contact details below. Unsubscribing from promotional communications will not stop service related communications from us, such as administrative alerts in relation to your account.
We may use and disclose your personal information to carry out consumer and market research, compile demographics and perform other research and analysis so that we can develop and implement initiatives to improve our services, improve the design, construction and operation of our products and services and to identify people likely to be interested in our products and services.
Who do we disclose personal information to?
We may disclose your personal information to:
- your representatives, advisers and others that you have authorised to interact with us on your behalf;
- our employees and third parties including business partners, consultants, contractors, suppliers, service providers, professional advisers and agents who need the information to assist us with conducting our business activities;
- related entities within our corporate group;
- prospective purchasers of all or part of our business or shares in our company or a related entity;
- government agencies or authorities, regulators, law enforcement agencies and other parties where authorised or required by law who ask us to disclose that information and to which we are legally required to disclose your personal information; and
- parties identified at the time of collecting your personal information or as otherwise authorised by you.
Disclosure to international recipients
We may disclose information to recipients that are located outside the country in which you are located (including contractors and third party service providers). We may disclose your personal information to our employees overseas as necessary to provide you with our goods and services.
At the time of writing we have related entities and service providers located in Australia, the United Kingdom, the United States of America, Brazil, Chile, Colombia (also covering Panama, Ecuador, Venezuela), India, Mexico, South Africa (covers Southern Africa), Indonesia and Peru (also covering Bolivia) , and may disclose personal information to those entities. As our network of related entities and service providers expands the list of countries in which our services are provided will increase.
By using our products or services (including our website) and providing us with your personal information, you consent to the disclosure by us, and to the storage and use of your personal information in the countries listed above which may be other than the country in which you are located where a different privacy or data protection regime applies.
How do we store and secure your personal information?
We take reasonable steps to ensure that any of your personal information which we hold is accurate, complete and up-to-date. These steps include promptly updating personal information when we are advised that personal information has changed, checking our contact lists for accuracy, and providing individuals with a simple means to update their personal information.
We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers (which may be located off-shore). Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time. These measures include:
- restricting access to our physical and electronic databases, and physical security such as security procedures for access to our business premises; and
- technological security procedures including password protection, network firewalls, encryption, intrusion detection and site monitoring where practicable to do so.
We also take steps to monitor access to and modification of your information by our employees and contractors, and ensure that our employees and contractors are aware of and properly trained in their obligations for managing your privacy.
However, the internet is not a secure environment and no matter what physical and technical security processes and procedures are used we cannot guarantee the security of your personal information. You also play an important role in keeping your information secure by maintaining the confidentiality of any usernames and passwords you use with our products and services (including our website).
How long do we store your personal information?
Personal information is only retained for as long as it is needed for the purpose for which it was collected or as required by law. Within a reasonable time after the expiry of this period, we will take reasonable steps to de-identify or destroy the personal information which is in our possession or control.
How can you access, restrict the use of, correct or transfer your personal information?
You have a right to:
- request a copy of your personal information,
- withdraw any consent previously given by you to the processing of your personal information;
- ask us to restrict the use of your personal information; and
- correct or rectify any personal information that is out-of-date, incorrect, incomplete or misleading.
Such requests should be submitted to us in writing using the contact details below.
We will action your request within a reasonable time frame and provide one copy of your personal information free of charge. If your request is for additional copies or your request is manifestly unfounded, excessive or repetitive, we may refuse your request or charge a reasonable fee. If we refuse a request or charge a reasonable fee, we will advise you of the reasons for our refusal or any fees within a reasonable time frame.
You have a right to request a copy of the personal information you have provided to us in a structured, commonly used and machine-readable format and the right to have that information transmitted or ported to another entity under certain circumstances.
There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy, rights or freedoms of others, or result in a breach of confidentiality or applicable laws. In these cases we will let you know why we cannot comply with your request.
How can you erase your personal information?
You have a right to request the erasure or destruction of your personal information when it is no longer necessary for the purpose for which it was originally collected, it is not being used for the purposes for which it was collected, or you wish to withdraw your consent for certain processing.
There may be cases where we are unable to comply with your request such as where we need to continue processing your personal information in order to comply with applicable laws. Such requests should be submitted in writing using the contact details below.
Privacy concerns or complaints
If you have a concern about your privacy or how we have handled your personal information, or you have a query on how your personal information is collected, please contact our Privacy Officer using the contact details below.
If you wish to make a complaint about the way we have handled your personal information including if you think we have breached the Privacy Act, you should forward a written complaint to our Privacy Officer using the contact details below. In the complaint, please include your contact details (such as email address, name, address and telephone number) and clearly describe the complaint.
We will respond to your query or complaint within a reasonable time. If you are not satisfied with our response, you may contact us to discuss your concerns. You may also contact the relevant privacy or data protection regulator, such as:
- Australia: the Office of the Australian Information Commissioner (OAIC) using the contact details at the OAIC’s website (https://www.oaic.gov.au/)
- United Kingdom: the Information Commissioner’s Office (ICO) using the contact details at the ICO’s website (https://ico.org.uk/)
DINGO Privacy Officer
Last updated: 23 March 2018