Privacy and security policy
"We", "us" and "our" means On Brand Investments Pty Ltd ACN 606 816 639 of Level 2, 61 Petrie Terrace, Brisbane, QLD, 4000.
You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
What is personal information?
Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
What personal information do we collect and hold?
We collect information about you and your interactions with us, for example, when you purchase or use any of our products or services, call us, interact with our chatbot or otherwise visit our websites (www.outfit.io or www.make.cm) The information we collect from you may include:
a) Identity information
We may collect personal details including but not limited to an individual’s name, location, date of birth, nationality, details of licenses & registrations, associations, family details, passwords, employment details, information provided to complete a security form, and third-party usernames and other information that allows us to identify an individual.
b) Contact information
We may collect information including but not limited to an individual’s email address, telephone & fax number, third-party username, residential, business and postal address and other information.
c) Statistical information
We may collect information about an individual’s online and offline preferences including but not limited to his or her habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes.
d) Information sent to us
We may collect any personal information or correspondence that individuals send us, or that is sent to us about individuals.
We may also collect your history of purchases and use of our products and services and details of enquiries or complaints you make.
We may collect information about how you access, use and interact with our websites and services. This information may include:
a) the location from which you have come to the site and the pages you have visited; and
b) technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.
We do not generally collect health, criminal, medical and other sensitive information about individuals except in the case of storing electronic versions of security forms for some of our users.
You can see our full cookies policy here.
Why do we collect, hold and use your personal information?
We collect, hold and use your personal information so that we can:
a) provide you with products and services, and manage our relationship with you;
b) improve our products and services;
c) verifying your identity;
d) contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
e) comply with our legal obligations and assist government and law enforcement agencies or regulators; or
f) identify and tell you about other products or services that we think may be of interest to you.
If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.
How do we collect your personal information?
We will collect your personal information directly from you whenever you interact with us.
We may collect information from third parties such as your employer, where your employer is our customer and you need to be provisioned with access to our products or services.
We may also receive personal information about you from sources such as users of our products and services, advertising, public records, mailing lists, contractors, staff, recruitment agencies and our business associates.
How do we store and hold personal information?
We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.
We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
These processes and systems include:
a) the use of identity and access management technologies to control access to systems on which information is processed and stored;
b) requiring all employees to comply with internal information security policies and keep information secure;
c) requiring all employees to complete training about information security; and
d) monitoring and regularly reviewing our practise against our own policies and against industry best practice.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
Who do we disclose your personal information to, and why?
We may transfer or disclose your personal information to our related companies.
We may disclose personal information to external service providers so that they may perform services for us or on our behalf.
We may also disclose your personal information to others outside our group of companies where:
a) we are required or authorised by law to do so;
b) you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
c) we are otherwise permitted to disclose the information under the Privacy Act.
If the ownership or control of all or part of our business changes (or is proposed to changed), we may transfer your personal information to the new owner (or proposed new owner).
We will not sell the personal information of individuals to unrelated third parties under any circumstances.
Do we disclose personal information to overseas recipients?
We may disclose your personal information to recipients which are located outside Australia. Those recipients are likely to be located in the United Kingdom or the United States of America.
Do we use your personal information for marketing?
We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
Access to and correction of your personal information
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
The United Kingdom has its own UK General Data Protection Regulation (“UK GDPR”) which is based on the European General Data Protection Regulation.
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
If you have any questions, comments, requests or concerns, please contact us by email at firstname.lastname@example.org marked for the attention of the Privacy Officer.
Changes to this policy
From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.
You may obtain a copy of our current policy from our website or by contacting us at the contact details above.
Last updated: June 23, 2021