Each Zapala Group member maintains Zapala Sites and provides services which may result in that member of the Zapala Group collecting your personal information (the “Services”).
The provision of the Services may involve the collection, use, disclosure and/or storage of data about a company or individual. That data can include personal information. “Personal information” is information about an individual which is capable of identifying that individual, and may include information such as the individual’s name, email address, telephone number, volume of consignment, shipping details and financial information.
How and when Zapala collects your personal information
Zapala may collect personal information directly from you when you:
- create an account on a Zapala Site or register to use a Service,
- use a Service,
- contact the Zapala support team; or
- visit a Zapala website.
You can always choose not to provide your personal information to Zapala, but it may mean that we are unable to provide you with all or part of a Service.
Zapala may receive personal information from you about others
Where requested to do so by Zapala, you must also assist Zapala with any requests by the individual to access or update the personal information you have collected from them and disclosed to Zapala.
Zapala collects, holds, and uses your personal information for limited purposes
Zapala collects your personal information so that we can provide you with the Services and any related services you may request. In doing so, Zapala may use the personal information we have collected from you to provide the Services and for purposes related to the Services including:
- verifying your identity,
- administering the Service,
- notifying you of new Services or changes to existing Services,
- carrying out marketing or training relating to a Service,
- assisting with the resolution of technical support issues or other issues relating to the Services,
- complying with laws and regulations in applicable jurisdictions;
- communicating with you about the Services and about Zapala Group generally; and
- any other purposes reasonably connected to any of the foregoing.
Zapala can aggregate your non-personally identifiable data
By using a Service, you agree that Zapala can access, aggregate and use non-personally identifiable data Zapala has collected from you and can manually de-identify personal information to create a non-personally identifiable dataset. This data will in no way identify you or any other individual.
Zapala may use this aggregated non-personally identifiable data to:
assist us to better understand how our customers are using the Services;
provide our customers with further information regarding the uses and benefits of the Services;
- enhance business productivity, including by creating useful business insights from that aggregated data and allowing you to benchmark your business’ performance against that aggregated data; and
- otherwise to improve the Services.
Zapala holds your personal information on servers located in Australia
All data, including personal and non-personal information, that is entered into the Service by you, or automatically imported on your instruction, is transferred to Zapala’s servers as a function of transmission across the Internet. By using the Service, you consent to your personal information being transferred to our servers as set out in this Policy.
Currently our servers are located in the cloud, hosted primarily by Microsoft (Azure). Your personal information will be routed through, and stored on, those servers as part of the Service. If the location of our servers changes in the future, we will update this Policy. You should review our Policy regularly to keep informed of any updates.
By providing your personal information to Zapala, you consent to Zapala storing your personal information on servers hosted outside of Australia. While your personal information will be stored on servers located in Australia, it will remain within Zapala’s effective control at all times. The server host’s role is limited to providing a hosting and storage service to Zapala, and we’ve taken steps to ensure that our server hosts do not have access to, and use the necessary level of protection for, your personal information.
Zapala takes steps to protect your personal information
Zapala is committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your personal information is stored on secure servers that have SSL Certificates issued by leading certificate authority Trustwave, and all data transferred between you and the Services is encrypted.
However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that your information will be secure at all times. Transmission of personal information over the Internet is at your own risk and you should only enter, or instruct the entering of, personal information into the Service within a secure environment.
We will advise you at the first reasonable opportunity upon discovering or being advised of a security breach where your personal information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.
If you are an account holder it is your responsibility to keep your password to the Services safe. You should notify us as soon as possible if you become aware of any misuse of your password, and immediately change your password within the Service or via the “Forgotten Password” process.
Zapala only discloses your personal information in limited circumstances
Zapala will only disclose the personal information you have provided to us to entities outside the Zapala Group if it is necessary and appropriate to facilitate the purpose for which your personal information was collected pursuant to this Policy, including the provision of the Services. You expressly consent to the disclosure of your personal information to members of the Zapala and their related bodies corporate. Zapala may provide your personal information to third party service providers who assist Zapala in providing the Services or to other third parties for related purposes such as credit reporting and transaction processing services and you expressly consent to the transfer of your personal information for such purposes, in each case on a worldwide basis.
Zapala will not otherwise disclose your personal information to a third party unless you have provided your express consent. However, you should be aware that Zapala may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas, or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.
The third parties who host our servers do not control and are not permitted to access or use your personal information except for the limited purpose of storing the information. This means that, for the purposes of Australian privacy legislation and Australian users of the Service, Zapala does not currently “disclose” personal information to third parties located overseas.
You may request access to your personal information
It is your responsibility to ensure that the personal information you provide to us is accurate, complete and up-to-date. You may request access to the information we hold about you, or request that we update, correct or delete any personal information we hold about you, by setting out your request in writing and sending it to us at email@example.com. Upon receipt of your request, we may seek information from you to confirm you are the person to whom the personal information relates prior to processing your request.
Zapala will process your request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know why. For example, it may be necessary for us to deny your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for us to process your request in the manner you have requested.
You may also delete your customer's information. Our Services and related documentation give you the ability to delete certain information about you or your customer from within the Service. For example, you can remove content that contains information about you using the keyword search and editing tools associated with that content and you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
We’ll only keep your personal information for as long as we require it for the purposes of providing you with the Service. However, we may also be required to keep some of your personal information for specified periods of time, for example, under certain laws relating to corporations, money laundering, and financial reporting legislation.
In providing the Services, Zapala utilises “cookies”. A cookie is a small text file that is stored on your computer for record-keeping purposes. A cookie does not identify you personally or contain any other information about you, but it does identify your computer.
We and some of our affiliates and third-party service providers may use a combination of “persistent cookies” (cookies that remain on your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when you close your browser) on the Zapala Sites to, for example, track overall site usage, and track and report on your use and interaction with ad impressions and ad services.
You can set your browser to notify you when you receive a cookie so that you will have an opportunity to either accept or reject it in each instance. However, you should note that refusing cookies may have a negative impact on the functionality and usability of the Services.
You can opt-out of any email communications
Zapala sends billing information, product information, Service updates and Service notifications to you via email. Our emails will contain clear and obvious instructions describing how you can choose to be removed from any mailing list not essential to the Service. Zapala will remove you at your request.
You are responsible for transfer of your data to third-party applications
Zapala has a privacy complaints process
If you wish to complain about how we have handled your personal information, please provide our Privacy Officer with full details of your complaint and any supporting documentation:
- by email at firstname.lastname@example.org; or
- by letter to The Privacy Officer, Zapala People Pty Ltd, Level 13, 8/327 Pitt St, Sydney NSW 2000, Australia.
Our Privacy Officer will endeavour to:
- provide an initial response to your query or complaint within 10 business days; and
- investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.
This policy may be updated from time to time
Zapala reserves the right to change this Policy at any time, and any amended Policy is effective upon posting to this Website. Zapala will make every effort to communicate any significant changes to you via email or notification via a Service.
Your continued use of the Service will be deemed acceptance of any amended Policy.
LAST UPDATED ON MAY 25th 2018