Privacy Policy

Background

Crave Holdings Pty Ltd (Crave Holdings, We, Our, Us and other similar terms) takes all reasonable steps to implement processes and procedures for the responsible management of personal information.

We have implemented this Privacy Policy in accordance with the Australian Privacy Principles (APP) and other data protection rules in order to be open and transparent about how We collect, hold, and use Your personal information, and under what circumstances We may disclose or transfer it.

This Privacy Policy applies to all personal information collected by Crave Holdings Pty Ltd in the course of providing products and services to Our customers (You, Your and other similar terms), regardless of its source, and forms part of the terms and conditions of our various agreements with You.

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.

Collection

3.1 Collection of Personal Information

We collect personal information:

• when You interact with us online, over the phone, by email, in person or through other means of communication; and
• in order to assist You with the provision of products and services and to provide any related assistance or for other purposes requested through such communication.

The type of personal information We collect includes Your name, telephone number, website, email address, company, relevant Facebook data, IP addresses, and any additional information You provide to Us.

Where You contact Us on behalf of Your employer, the information You provide often contains information about Your employment, position and employer’s contact details. In those circumstances, certain employment information is collected.

Information will only be collected directly from You unless You authorise another person to provide the information.

3.2 Device Information and Cookies

When You visit our website, We may collect certain information about Your device, including details about Your web browser, IP address, time zone, and some of the cookies that are installed on Your device. Additionally, as You browse, We collect information about the individual web pages, products and services You view, what websites or search terms referred You, and information about how You interact with Us online.

We collect device information using the following technologies:

• “Cookies” – data files placed on Your device or computer which may include an anonymous unique identifier;
• “Log files” – track actions occurring on the website, and collect data including Your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps;
• “Web beacons”, “tags”, and “pixels” – electronic files used to record information about how You browse Websites.

Please note that We do not alter our website’s data collection and use practices when We see a “Do Not Track” signal from Your browser.

Through Our use of Google Analytics, the information generated by the cookie about Your use of the website (including Your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating Your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf.

You may refuse the use of cookies by selecting the appropriate settings on Your browser. However, if You do so, You may not be able to use the full functionality of Our website.

Consent

By agreeing to this Privacy Policy, You give Us Your consent to use Your personal information as set out herein. You have a right to withdraw Your consent at any time and may do so by contacting Us via the details provided below.

By using our website, You consent to the processing of data about You by Google in the manner described in Google’s privacy policy and for the purposes set out above. You can opt out of Google Analytics if You disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

Use

5.1 General Use

We use personal information collected as part of Our business operations which are primarily associated with the development and sale of digital marketing solutions. Examples of when Your information may be used include:

• informing You about Our products and services;
• providing You with the products and services requested;
• administration requirements in relation to providing You with products and services, including managing Your account;
• dealing with requests, enquiries or complaints and other customer care related activities;
• engaging with the support of our products and services;
• marketing Our products and services generally; and
• 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.

We may also use personal information for purposes as would be reasonably expected by You in connection with those activities described above. However, We will not use Your personal information for purposes other than as described in this Privacy Policy or other agreement We have with You, unless You consent to that use or there are specific law enforcement, public health or safety reasons.

5.2 Direct Marketing

From time to time, we undertake direct marketing campaigns targeted at the contacts in our database who have consented to receive this type of communication from Us.

Accessing Your Information

Upon Your request and after satisfying ourselves of Your identity, We will provide access to the personal information We hold about You except in certain prescribed circumstances. These include where:

• We believe giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
• giving You access would be unlawful;
• granting access would have an unreasonable impact on the privacy of other individuals;
• the request for access is frivolous or vexatious; or
• there are anticipated legal proceedings.

Data Integrity

We take reasonable steps to ensure the personal information We collect, use and disclose is accurate, complete and up to date. You have a right to correct incorrect information at any time and may do so by contacting Us using the details provided below.

If You become aware Your information is no longer accurate, complete or up-to-date, please contact Us.

Sharing Information

We may disclose personal information to:

• employees, a related entity and Our professional advisors, such as Our lawyers and accountants;
• law enforcement agencies to assist in the investigation and prevention of criminal activities; and
• Our third-party contractors or service providers with whom We have a business association.

Finally, We may also share Your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information We receive, or to otherwise protect Our rights.

We will not disclose Your personal information other than in accordance with this Privacy Policy without Your consent.

Anonymity and Use of Pseudonyms

We may interact with You anonymously or through the use of pseudonyms if Your questions are general in nature. However, You are required to provide true and accurate details when requesting the supply of products or provision of services. You agree to provide accurate information if so required.

Security

We take commercially reasonable steps to protect the personal information We hold from misuse, loss and unauthorised access, modification or disclosure. We do this by:

• maintaining and keeping Our systems up to date;
• using secure servers protected from unauthorised access, modification or disclosure;
• using secure sockets layer (SSL) encryption to transfer data across public networks;
• relying on reputable service providers; and
• limiting the collection of Your personal information to that which We reasonably require.

Data Retention

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 APPs 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.

We envisage Your personal information will be deleted or de-identified within ten (10) years if it is no longer reasonably required.

You may make a request to Us in writing to remove Your personal information and, where permitted, We will do so in accordance with the APPs and the GDPR.

Additional Rights Under the GDPR

If You are an EU resident or citizen, You have the right to access the personal information We hold about You and to ask that Your personal information be corrected, updated, or deleted. You may also object to the processing of Your personal information.

Complaints Procedure

Crave Holdings Pty Ltd is a customer service-oriented business. Therefore, if You have a complaint about Our collection or use of personal information pertaining to You, then We ask You to contact Us. Our Privacy Officer can be contacted via the information provided below.

If after investigating Your complaint and reporting Our findings, You are still not satisfied, then We ask You to consult:

The Office of the Australian Information Commissioner
GPO Box 5218
Sydney, NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

Alternatively, if You are an EU resident or citizen You may contact Your local supervisory authority.

Contacting Us

For more information about our privacy practices, if You have questions, or if You would like to make a complaint, please contact Us using the details provided below:

Address enquiries to: Crave Holdings Pty Ltd – Privacy Officer
Telephone: 0438 370 369
Email: hello@crave.com.au 

Amendments

We are obligated to regularly review and update this Privacy Policy. As such, We may update this Privacy Policy from time to time in order to reflect changes to Our practices or for other operational, legal or regulatory reasons.