Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information/personal data provided to us, or otherwise collected by us, offline or online, including through this website (Site).

In this Privacy Policy we, us or our means @ WWW Pty. Ltd. trading as The Dubs ACN 071 461 875.

This Privacy Policy takes into account the requirements of the Australian Privacy Act 1988 (Cth) (Australian Privacy Act) and the Australian Privacy Principles.

In addition to the Australian laws, this Privacy Policy also takes into account the UK Data Protection Act 2018 and the UK General Data Protection Regulation 2016/679 (as incorporated into UK law, known as the UKGDPR), each as amended pursuant to UK’s The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

This Privacy Policy contains:

THE CONSENTS AND ACKNOWLEDGEMENTS YOU GIVE US BY PROVIDING YOUR PERSONAL INFORMATION/PERSONAL DATA TO US (SEE “CONSENTS AND ACKNOWLEDGMENTS” BELOW);

how you may access the personal information/personal data about you we hold and seek access to, erasure of, correction to or portability of such information (see “Access, Erasure and Correction/Rectification” below);

how you may complain to us and how we will deal with such a complaint (see “Complaints” below);

whether we are likely to disclose personal information/personal data to overseas recipients and what the consequences of that might be (see “Disclosure of personal information/personal data to third parties” below); and

how to opt out of direct marketing communications from us (see “CONSENTS AND ACKNOWLEDGEMENTS” below).

Consents and acknowledgements

Your choice: Please read this Privacy Policy carefully. By providing personal information/personal data to us:

you acknowledge that you have read our Privacy Policy and that it sets out how we collect, hold, use, process and disclose your personal information/personal data; and

you explicitly consent to:

the collection, holding, use, processing or disclosure of personal information/personal data by @ WWW Pty Ltd ACN 071 461 875, an Australian incorporated proprietary company trading as The Dubs in accordance with our Privacy Policy, including in particular without limitation the disclosure of personal information/personal data to business partners, including Dianomi PLC, a United Kingdom incorporated public company with registered no. 04513809, who may use it for the purposes of direct marketing;

the disclosure of personal information/personal data by @ WWW Pty Ltd ACN 071 461 875, an Australian incorporated proprietary company trading as The Dubs, to overseas recipients in jurisdictions including the United Kingdom where we reasonably believe Australian Privacy Principle 8.1 is not required to apply, therefore if you consent to that disclosure and the overseas recipient handles personal information in breach of the Australian Privacy Principles:

we will not necessarily be accountable under the Australian Privacy Act (although the overseas recipient may be accountable under their local law and regulation, but the applicable privacy obligations and principles may differ from the Australian Privacy Principles);

you may not be able to seek redress against us under the Australian Privacy Act (although you may have redress against the overseas recipient under their local law and regulation, but the redress may be different from that available in Australia); and

the overseas recipient may be subject to foreign laws that could compel the disclosure of personal information/personal data to a third party such as an overseas authority; and

you acknowledge that:

the provision of personal information/personal data to us is not a pre-condition to receipt of all our services and you have had a genuine opportunity to withhold consent;

you have been properly and clearly informed of the implications of providing consent;

we are entitled to presume that you have capacity to give consent in accordance with this Privacy Policy; and

you would reasonably expect us to use or disclose your personal information/personal data for the purpose of direct marketing.

Our third party business partners, including without limitation Dianomi PLC, a United Kingdom incorporated public company with registered no. 04513809, may rely on the consents and acknowledgments you give.

Withdrawing Consent:

In addition to any opt-out option included in communications with you, you may, by written notice at any time to our Data Protection/Privacy Officer at the contact details below and at no further cost to you, withdraw your consent to:

any future holding, use, processing or disclosure of your personal information/personal data for any purpose; or

any future disclosure of your personal information/personal data to an overseas recipient,

without affecting the lawfulness of collection, holding, use, processing or disclosure based on consent before its withdrawal.

Consent to our collection, holding, use, processing and/or disclosure of your personal information/personal data is not a pre-condition to the provision of all of our services, please contact our Data Protection/Privacy Officer should you seek alternatives, but we may find it more difficult to provide you with continued access to our services or those of our business partners such as Dianomi PLC in the event of your not consenting or withdrawing consent to our collection, holding, use, processing and/or disclosure of your personal information/personal data.

In order to:

object to holding, use or processing of personal information/personal data by us for direct marketing;

object to disclosure of personal information/personal data by us for direct marketing by third parties;

unsubscribe from our email database; or

opt-out of communications (including marketing communications) from us,

please contact us using the details below or opt-out using the opt-out facilities provided in the communication. Direct marketing communications will be stopped at no further cost to you within a reasonable period of that request, which would generally be no more than 30 days. Facilities for opting out of direct marketing from our business partners such as Dianomi PLC should also be made available to you by them – that facility in respect of Dianomi PLC is available at https://www.dianomi.com/legal/privacy.epl

Access, Erasure and Correction/Rectification:

You have rights to request:

access to;

correction/rectification of;

erasure of;

restriction of processing of; and

portability (i.e. the transfer to a third party),

of personal information/personal data we hold in respect of you.

If you wish to access, erase, restrict the processing of or transfer any personal information/personal data we hold about you, or if you believe that any personal information/personal data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact our Data Protection/Privacy Officer using the details below.

We will take reasonable steps to promptly correct any personal information/personal data found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint.

You also have the right to contact relevant authorities including the Information Commissioner in the United Kingdom (see https://ico.org.uk/make-a-complaint/) and the Office of the Australian Information Commissioner in Australia (seehttps://www.oaic.gov.au/privacy/privacy-complaints/).

Personal information/personal data

Personal information/personal data: The types of personal information/personal data we may collect about you include:

your first name and last name;
your contact details including email address and telephone number;
details of products and services we have provided to you and/or that you have enquired about, and our response to you;
your preferences and/or opinions;
information you provide to us through customer surveys;

your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
additional personal information/personal data that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media applications and/or accounts from which you permit us to collect information; and
any other personal information/personal data requested by us and/or provided by you or a third party.

We may collect these types of personal information/personal data directly from you or from third parties and not generally from publicly accessible sources. If we did not collect this personal information/personal data, in our view it would be less practicable for us to provide services to you through your use of the Site.

Collection and use of personal information/personal data

The legal basis for our processing of your personal information/personal data is your explicit consent. It is not presently possible for our business to obtain separate consents for each of the purposes described below, but you may withdraw consent on a granular basis. We may collect, hold, process, use and disclose personal information/personal data for the following purposes:

to enable you to access and use our Site, associated applications and associated social media applications;
to contact and communicate with you, including to send our newsletters;
to perform our marketing content services for you;

for internal record keeping, administrative purposes, invoicing and billing purposes;
for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
to run promotions and/or offer additional benefits to you;
for advertising and marketing, including direct marketing, including sending you promotional information about our products and services and information that we consider may be of interest to you;
to comply with our legal obligations and resolve any disputes that we may have; and

if you have applied for employment with us; to consider your employment application.

Disclosure of personal information/personal data to third parties

We may disclose personal information/personal data to:

third party service providers for the purpose of enabling them to provide their services to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities;

our existing or potential agents or business partners, including without limitation Dianomi PLC, any of whom may use that personal information/personal data for direct marketing purposes subject to the privacy laws applicable to that direct marketing;
sponsors or promoters of any competition we run;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia, including:

the United Kingdom;
countries subject to an adequacy regulation of the United Kingdom including:

the European Economic Area (EEA) countries including:
the European Union (EU) member states being Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden;

the EFTA countries being Iceland, Norway and Liechtenstein;
Gibraltar;
countries covered by the European Commission’s adequacy decisions including:
Andorra, Argentina, Faroe Islands, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland and Uruguay; and
Japan and Canada in certain circumstances;

other countries including the United States of America subject to appropriate and suitable safeguards, a copy of which is available upon request from the Data Protection/Privacy Officer,

in respect of all of which jurisdictions we reasonably believe that Australian Privacy Principle 8.1 is not required to apply; and

third parties to collect and process data, such as Google Analytics. This may include parties that store data outside of Australia, including in the jurisdictions above in respect of which we reasonably believe Australian Privacy Principle 8.1 is not required to apply.

Data Transfers

The countries to which we send data for the purposes listed above may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information/personal data to third parties in other countries we will perform those transfers in accordance with the requirements of applicable law.

How we treat personal information/personal data that is also sensitive information/special category data

Sensitive information/special category data is a sub-set of personal information/personal data that is given a higher level of protection under the Australian Privacy Principles and UK GDPR. Sensitive information/special category data means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.

We do not aim to collect sensitive information/special category data, but it we do, provided you consent, your sensitive information/special category data may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information/special category data was collected.

Sensitive information/special category data may also be used or disclosed if required or authorised by law.

Our commitment to you

Your personal information/personal data will:

be processed lawfully, fairly and in a transparent manner by us;
only be collected for the specific purposes we have identified in the ‘collection and use of personal information/personal data’ clause above and personal information/personal data will not be further processed in a manner that is incompatible with the purposes we have identified;
be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information/personal data is processed;
be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information/personal data);

be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal information/personal data was collected;
be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Information from third parties: If we receive personal information/personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information/personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal information/personal data to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us. We have concluded it is not practicable for us to give you the option of not identifying yourself or using a pseudonym when providing you with our Special Research Reports.

Storage and security

We are committed to ensuring that the personal information/personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information/personal data, to safeguard and secure personal information/personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information/personal data we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Data Retention

We are not able to specify in advance the period for which your personal information/personal data will be stored, but we will only retain your personal information/personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information/personal data, we consider the amount, nature, and sensitivity of the personal information/personal data, the potential risk of harm from unauthorised use or disclosure of your personal information/personal data, the purposes for which we process your personal information/personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information/personal data (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.

Cookies and web beacons

We and our third party ad networks may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information/personal data, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We and our third party as networks may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

Links to other websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information/personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

It is our intention regularly to review and update our Privacy Policy to ensure our Privacy Policy reflects our information handling practices at a minimum as part of our annual planning processes. We may therefore, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change. You are invited to comment on our Privacy Policy to our Data Protection/Privacy Officer at the contact details below and any comments will be given due consideration.

For any questions or notices, please contact our Data Protection/Privacy Officer at:

@ WWW Pty Ltd trading as The Dubs ACN 071 461 875

Tel:

Australia: WeWork, Level 3 100 Harris Street, Pyrmont, 2009

UK: 126C, Parkshot House, 5 Kew Road, Richmond, Surrey, TW9 2PR

Email: contactus@thedubs.com

Last update:September 2021