1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons. In other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, "we", "us" and "our" refer to JWAM Portal Pty Ltd. For more information about us, see Section 15.
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your site Administrator. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your site Administrator, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the profile data is you and/or your site Administrator. If you log into our website using a social media account, we will obtain elements of the profile data from the relevant social media account provider.
2.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.7 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Publications - We may process account data and/or profile data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.4 Relationships and communications - We may process contact data, account data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, and/or telephone, providing support services and compliance handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of relationships, and the proper administration of our website, services and business.
3.5 Personalisation - We may process account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
3.6 Direct marketing - We may process contact data, account data and profile data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.7 Research and analysis - We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.8 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.9 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.10 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.11 Legal claims - We may process your personal data where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 Contact, account, profile, communication and usage data will be retained for a minimum period of 6 years following the date of the most recent communication between you and us, and at our discretion following that date
4.5 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 We reserve the right to retain your personal data unless required by law to delete or relinquish this data.
5.2 Your profile data may be retained and remain viewable even following the cancellation of any paid membership to our website.
5.3 Your profile data may only be removed from the website at our sole discretion. In the event that we are requested to delete your personal data or remove your profile data from the website, we will require payment of any foreseeable costs and commercial loss arising from or associated with the removal of your profile data from the website prior to implementing the removal of the requested data from our site and servers. We estimate that those costs could range from $15,000 to $50,000 depending on the nature of the information to be removed.
5.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your site page when logged into our website.
5.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5.5 You may exercise any of your rights in relation to your personal data by written notice to us.
6.1 Our website includes hyperlinks to, and details of, third party websites.
6.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
7.1 Our website and services are targeted at persons over the age of 16.
7.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
8.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.1 In respect of any data uploaded to an Alumni Site by a site Administrator or Alumni we do not act as a data controller; instead, we act as a data processor.
9.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
(a) authentication and status - to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;
(b) personalisation - to store information about your preferences and to personalise the website for you;
(c) security - as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(d) advertising - to help us to display advertisements that will be relevant to you;
(e) analysis - to help us to analyse the use and performance of our website and services; and
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
13.2 Blocking all cookies may have a negative impact upon the usability of many websites.
13.3 If you block cookies, you may not be able to use all the features on our website.
14.1 We may update this policy from time to time by publishing a new version on our website.
14.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14.3 We may notify you of significant changes to this policy by email.
15.1 This website is owned and operated by JWAM Portal Pty Ltd.
15.2 We are registered as a business in Australia under ABN 24 602 502 983, and our registered office and principal place of business is at 321 Moorabool Street, Geelong, Victoria 3220.
15.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form; or
(c) by telephone, on the contact number published on our website.