CERPASS Software Privacy Policy

1. Background

Thanks for visiting our Privacy Policy (Policy), we are CERP R&D Pty Ltd t/a CERPASS Software ACN 616 511 801 of Level 4, 155 Queen St, Brisbane QLD 4000 (CERPASS Software, we, our, us and other similar terms). We are committed to providing quality services to you and this policy outlines our ongoing obligations in respect of how we manage your Personal Information. It applies to our CERPASS Terms of Use and other agreements we may form with you.

When we talk about Personal Information, we mean information or an opinion about an identifiable individual (not a company), whether or not that information or opinion is true or in a material form (Personal Information).

2. Disclaimer

While your Privacy is important to us, nothing in this Privacy Policy constitutes a voluntary opt-in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with.

3. Collection of Personal Information

3.1 How we collect Personal Information

We collect Personal Information in the ordinary course of our business, which is the provision of a cloud-based software application that provides clients the capability to assess, manage and control SAP access risk. Personal Information is collected when you:

(a) contact or correspond with us via email, telephone or via our website;

(b) when a CERPASS Account is created for you;

(c) interact with us via our social media channels such as LinkedIn, Facebook and Twitter;

(d) subscribe to our newsletters or complete surveys and online forms;

(e) or your employer use CERPASS for compliance monitoring;

(f) apply for employment with us;

(g) purchase or enquire about CERPASS;

(h) attend a CERPASS Software (or affiliate) event;

(i)  seek support in relation to CERPASS; or

(j) make customer service related enquiries.

Other than information contained within a SAP user account, information will only be collected directly from you unless you authorise another person to provide the information.

3.2 What Personal Information is collected?

The types of Personal Information we collect includes your name, address, telephone number, email, SAP user account details and any additional information provided to us.

Where you contact us on behalf of your employer or your employer makes use of CERPASS, the information you provide often contains information about your employment, position and employers contact details. In those circumstances certain employment information is collected.

Where you contact us in relation to a job application, we may also collect Personal Information such as your date of birth, gender, qualification details, education and academic history, work experiences and skills, next of kin, awards received and areas of interest.

4. How CERPASS Software uses Personal Information

4.1 Why we collect Personal Information

We collect your Personal Information for the primary purpose of providing CERPASS to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.

Examples of when we may use your Personal Information include:

(a) informing you about CERPASS or our events;

(b) providing you with access to CERPASS;

(c) in generating usage reports to CERPASS account holders;

(d) sending you magazines or electronic newsletters which you have signed up for;

(e) administration needs in relation to providing you with CERPASS, including the administration of your account;

(f) when communicating with Shipley Consultants Pty Ltd in relation to any application support enquiries you make;

(g) dealing with requests, enquiries or complaints and other customer care related activities; and

(h) carrying out any activity in connection with a legal, governmental or regulatory requirement imposed on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.

4.2 Direct marketing

Where you provide us with consent to do so (e.g. if you have subscribed to our email or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you.

We (or an appointed third party) may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the type, quality and the manner in which our goods and services are offered to you.

You can opt-out of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

5. Cookies and browser analytics

5.1 What are cookies?

Cookies are small text files that are placed on your computer by the websites you visit. They are processed and stored by your web browser. When you visit a website or engage with a business through social media, certain information is collected by cookies. This is generally anonymous information and it does not reveal your identity. In and of themselves, cookies are harmless and serve crucial functions. They are widely used in order to make websites work more efficiently and improve the user experience, as well as to provide information about the use of a website.

5.2 Why does CERPASS Software use cookies?

By storing and using information about your use of our website, including preferences and habits, we are able to make your visit to our website more productive. For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices.

5.3 How can I remove cookies?

Your web browser can choose whether or not to accept cookies. Most web browser software is initially set up to accept them. If you do not want your browser to use cookies, you can manage and control their use through your browser, including removing cookies by deleting them from your “browser history” (cache) when you leave the site. However, if you choose to reject cookies some parts of our website may not work properly.

6. Data retention and security

6.1 Security mechanisms we employ

Generally, we store your Personal Information using secure servers protected from unauthorised access, modification and disclosure. However, like most businesses we hold some information on our staff’s computers (such as emails from you) and where necessary as hard copy files (such as printed invoices).

Unless otherwise agreed with you, our systems are located in Australia and are managed by us and our service providers. Personal Information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption (such as SSL) where appropriate.

Data, including Personal Information, is processed on SAP Cloud Services in accordance with the Personal Data Processing Agreement in place between CERPASS Software and SAP. Further details about SAP Cloud security is provided in the annexures to the CERPASS terms of Use.

In our dealings with other third party service providers and subcontractors, we take care to work with those who we believe maintain an acceptable standard of data security compliance.

6.2 How long we keep your Personal Information

We retain your Personal Information for as long as is necessary to provide CERPASS to you, as required for our internal business operations, and to comply with our legal obligations

If we hold Personal Information about you, and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the Australian Privacy Principles (APP) and the European Union General Data Protection Regulation (GDPR), unless we are prevented from doing so by law.

Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions associated with those records are completed.

If you no longer want us to use your Personal Information, you can request that we erase it and close your account. Where possible we will do so in accordance with the APPs and GDPR. However, where you request the erasure of your Personal Information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. Any information we retain will be handled in accordance with this privacy policy.

7. Disclosure of your Personal Information

7.1 Who we share your Personal Information with

Your Personal Information may be disclosed to:

(a) our employees, a related company and our professional advisers (lawyers, accountants, financial advisers etc.);

(b) regulators and government authorities in connection with our compliance procedures and obligations, including law enforcement agencies to assist in the investigation and prevention of criminal activities;

(c) a third party, in order to enforce or defend our rights, or to address financial or reputational risks;

(d) a rights holder in relation to an allegation of intellectual property infringement;

(e) your employer if you have a SAP user account which is being monitored by CERPASS;

(f) third party contractors, suppliers and service providers with whom we have a business association, including:

(I) SAP by use of the SAP Cloud Services;

(ii) Shipley Consultants Pty Ltd in relation to CERPASS support enquiries;

(iii) administration service providers, such as Office 365 and Xero;

(iv) marketing and sales service providers, such as HubSpot; and

(v) other information technology and cloud application providers which we engage from time to time.

We will not disclose your Personal Information other than in accordance with this Policy without your consent.

7.2 Offshore transfers

While we do not otherwise actively disclose your Personal Information to overseas (outside of Australia) entities, our engagement of service providers, such as those who operate cloud services, may have international data centres and disaster recovery sites. Consequently, these providers may have access to your information offshore. We rely solely on reputable organisations for such cloud services.

8. Anonymity and use of pseudonyms

If you contact us with a general enquiry, we may interact with you anonymously or through the use of pseudonyms. However, you are required to provide true and accurate details when requesting the supply of goods or provision of services. You agree you will provide accurate information if we require it.

9. Access to Personal Information and corrections

We endeavour to only hold Personal Information that is accurate, complete and up-to-date. You have the right to make a request to access Personal Information which we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact us using the contact details provided at the end of this Policy.

If you have an account with us, you can access some of the Personal Information that we collect about you. By logging into your account, you can update or correct certain information.

In order to protect your Personal Information, when you contact us, we may require identification from you before releasing the requested information or making the correction.

10. Additional rights for EU residents and citizens

For the purposes of the GDPR, we are a ‘data controller and processor’ of Personal Information. If you are a citizen or resident of the European Economic Area, the following rights apply to you.

You are entitled to ask us to port your Personal Information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent.

These rights are limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your Personal Information. In some instances, this means that we may retain some data even if you withdraw your consent.

Where we require your Personal Information to comply with legal or contractual obligations, then provision of such data is mandatory and if you do not provide it then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In those cases, you must provide us with your Personal Information, otherwise the provision of requested Personal Information is optional.

If you have unresolved concerns, you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority in the country:

(a) of your habitual residence;

(b) of your place of work; or

(c) in which you consider the alleged infringement has occurred.

11. Complaints

Your privacy is important to us. If you have a complaint or concern about our handling of your Personal Information, we ask that you first contact our privacy officer whose contact details are listed below. We will investigate your complaint and reply to you in writing if you provide us with contact details and request us to do so.

If, after we have conducted our investigations you are still not satisfied then we ask you to consult with the Office of the Australian Information Commissioner:

Email: [email protected]

Telephone: 1300 363 992 (from overseas +61 2 9284 9749)

Post: GPO Box 5218 Sydney NSW 2001

12. Contacting CERPASS Software

If you have any questions about our privacy practices, wish to make a complaint or have questions regarding the way in which we have been managing your Personal Information, please contact our privacy officer:

Email: [email protected]

Telephone: (07) 3217 7778

Post: Level 4, 155 Queen St, Brisbane QLD 4000

13. Variations to this Policy

We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

 

 

This policy was last updated on 25 June 2020.

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