a reference to Australian Privacy Principles (APPs) means the APPs contained in the Privacy Act.
The kinds of PI that CounterPick generally collects from you are:
- residential address;
- date of birth;
- email address;
- phone number;
- personally submitted preferences and service usage information;
- bank account and credit card information;
- location data;
- IP address;
- behavioural data; and
- other identity verification information (i.e. licence and/or passport details).
CounterPick will collect your PI for the following purposes:
- to send you newsletters and other communications that you ask to receive from us or that relate to the services we provide to you;
- to process your application to become a member of CounterPick ("Member");
- to operate your ccount and to provide services to you as a Member;
- for market and business analysis and research;
- to develop new products and services and to tailor our services to suit your needs;
- to determine Members' liability to pay goods and services tax and other taxes where applicable;
- to comply with CounterPick’s legal and statutory obligations
- for taking appropriate action if CounterPick has reason to suspect that unlawful activity or misconduct of a serious nature has been, is being or may be engaged in that relates to our functions and activities;
- to respond to enquiries and complaints from you and to establish, exercise or defend any legal claims; and
- to the to the extent that the information is included in a job application, to assess and process that application and for other recruitment purposes.
You may choose to deal with us on an anonymous basis or to use a pseudonym unless it is not practicable for us to deal with
individuals who we cannot identify, or we are required by law to only deal with identified individuals (such as under the AML/CTF Act).
Also, if you do not provide CounterPick with the PI we request,
we may be unable to process your application to become a Member, provide you with our services or respond to your enquiry or complaint.
By becoming a Member or otherwise choosing to provide CounterPick with PI you consent to CounterPick collecting, using and disclosing your PI for the above purposes.
PI may also be collected by cookies when you use the website. Cookies are pieces of data stored by your web browser on your hard drive which contain
information relating to your use of the website. When you access the website, cookies may record details relating to your use of the website, including
We may use third-parties to serve ads on our website. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.
Direct marketing and opting out
From time to time we may use your PI to inform you about CounterPick's products or services or about promotional activities which CounterPick believes
may be of interest or of benefit to you. We may do this via email.
If you no longer wish to receive marketing or promotional material from CounterPick at all or in any particular form, you may contact us at any time by email to firstname.lastname@example.org with your request with which we will comply as soon as is practical.
From time to time we may contact you in relation to the management and administration of your CounterPick account. These communications can be via any of the modes of contact recorded when registering as a Member. Such communication does not affect your opt-in or opt-out status for direct marketing communications.
Management of your personal information
CounterPick will take all reasonable steps to ensure that the PI which it collects, uses or discloses is correct and is stored in a secure environment
which is accessed only by authorised persons.
CounterPick will destroy or permanently de-identify the PI we hold when it is no longer required for any purpose permitted under the APPs including our legal or operational obligations.
PI collected by CounterPick may be disclosed to a third party in the following circumstances:
- to provide you with the services or support/information you have requested;
- to service providers and professional advisers for the purposes of providing services to us;
- to our sponsors and business partners for the purposes of our business relationship with them;
- where the disclosure is required or authorised by law
- to related bodies corporate, and actual or prospective purchasers of all or a part of CounterPick's business, and their advisers; and
- where you have consented to its disclosure either expressly or by the circumstances and your conduct.
CounterPick will take reasonable steps to ensure that any PI which CounterPick discloses to a third party is protected by that party in accordance with the Privacy Act.
Security of Personal Information
You acknowledge that no data transmission over the Internet is totally secure. Accordingly, CounterPick does not warrant the security of
any information which you transmit to it. Any information which you transmit to CounterPick is transmitted at your own risk.
However, once CounterPick receives your transmission, CounterPick will take reasonable steps to protect your PI from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer ("SSL") technology. CounterPick’s employees, agents and contractors are required to maintain the confidentiality of Members' PI and behaviour.
Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms), including our website chat service, becomes public information. CounterPick cannot guarantee the security of this type of disclosed information.
We take seriously the responsibility to exclude children from access to our services. We will not accept their information for the purposes of opening an account. It is, however, ultimately the responsibility of parents or guardians to monitor their children’s Internet activities including where appropriate by using Internet screening software.
Remember to always log out of your account when you have completed your time on the website. This is particularly important if you share a computer with another person. You are responsible for the security of and access to your own computer, mobile device or any other handset used to access the website.
Ultimately, you are solely responsible for maintaining the secrecy of your username, password and any account information. Please be careful whenever using the Internet and our website.
Access to Personal Information
You may access the PI collected by CounterPick by following the Account link on the website or by contacting us by email on email@example.com. We will give you access to your PI in the manner requested if that is possible and within a reasonable period. If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. We may not be required to give you access to your PI in certain circumstances which are set out in the APPs including where it may have an unreasonable impact on other individual's privacy. If we refuse access for such reasons, we will advise you in writing of the refusal and our reasons and the complaint mechanisms available to you.
Correction and Continuous Updating of your Personal Information
CounterPick takes reasonable measures to ensure that PI which it collects is accurate, complete and current and also when it uses and discloses it,
that it is relevant, having regard to the purpose for which it is being used or disclosed. We will take reasonable measures to correct PI if we are
satisfied that it should be corrected. We may contact you on a periodic basis to seek the most up to date information from you.
If you believe that the PI CounterPick holds about you is inaccurate, incomplete or not current, please let CounterPick know and we will correct it if we are satisfied that a correction is required.
PI can be updated or corrected by you in the "Edit Account Info" section of the website at any time after you log in. Your match history can be found on the ‘Account’ section of the website.
If you have any queries, requests for access or correction or complaints relating to the handling of your PI, please contact us at firstname.lastname@example.org.
Further Information about privacy concerns or complaints in Australia can be found on the Office of the Australian Privacy Commissioner's (OAIC) website at www.oaic.gov.au.