Devote Privacy Policy
1. About this policy
Devote Digital Pty Ltd (ABN 86 619 264 603) of 11/156 Boundary Street, West End QLD 4101 (Devote, we, us, our) provides marketing, content and website services including brand strategy, design, community management, ambassador management, paid media, search engine optimisation, email marketing, conversion rate optimisation, content strategy, website development and more.
This policy explains how we collect, hold, use, disclose and protect personal information. It applies to our website at www.devotedigital.com.au, to our dealings with clients, prospective clients, suppliers and job applicants, and to the marketing campaigns and promotions we run on behalf of our clients.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
2. What personal information means
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form.
Sensitive information is a subset of personal information and includes health information, and information about racial or ethnic origin, political opinions, religious beliefs, sexual orientation and criminal record. We do not ordinarily collect sensitive information. Where we do, we collect it only with consent and only where it is reasonably necessary for our functions.
3. Whose information we handle
We handle personal information about:
a) visitors to our website;
b) prospective clients and people who contact us;
c) individual contacts at our client and supplier organisations;
d) individuals whose information our clients ask us to handle on their behalf, including their customers, subscribers and leads;
e) individuals who enter competitions, promotions or campaigns that we administer for clients;
f) individuals who follow, message or interact with social media accounts we manage for clients; and
g) job applicants and contractors.
4. What we collect
Depending on the relationship, we may collect:
a)Contact and identity information: name, email address, telephone number, postal address, business name, job title;
b)Commercial information: enquiry details, project and campaign records, correspondence, meeting notes and recordings where you have been notified, billing and payment details;
c)Marketing and behavioural information: email open and click activity, subscription and unsubscribe status, purchase history where a client provides it, campaign responses and competition entries;
d)Technical information: IP address, device and browser type, operating system, pages visited, referring source, session duration and advertising identifiers, collected through cookies and similar technologies;
e)Recruitment information: resumes, work history, qualifications, references and, where relevant and with consent, background check results.
We do not knowingly collect personal information from children under 18 except where a promotion or campaign is specifically directed at that audience and appropriate parental consent has been obtained.
5. How we collect it
We collect personal information directly from you wherever it is reasonable and practicable to do so. That includes when you contact us, complete a form on our website or on a campaign site we operate, subscribe to a mailing list, enter a promotion, meet with us, or apply for a role.
We also collect personal information from third parties, including:
a) our clients, where they engage us to work with their customer or subscriber data;
b) advertising and analytics platforms that report on campaigns we run;
c) publicly available sources, including business websites and professional networking platforms; and
d) recruiters and referees.
If we receive personal information about you that we did not solicit and could not have collected ourselves under the APPs, we will destroy or de-identify it as soon as practicable, provided it is lawful and reasonable to do so.
6. Why we collect and use it
We use personal information to:
a) respond to enquiries and provide our services;
b) plan, build, run, measure and report on marketing campaigns, both our own and our clients';
c) administer promotions and competitions, including judging entries and distributing prizes;
d) manage our client and supplier relationships, including billing;
e) send marketing communications where you have consented or where you would reasonably expect them, subject to section 10;
f) improve our website, services and internal processes;
g) assess job applications; and
h) meet our legal and regulatory obligations.
7. Personal information we handle for our clients
A significant part of our work involves handling personal information that belongs to a client's customers, subscribers or audience, for example when we manage a client's email marketing platform, advertising accounts or ecommerce store.
In those cases:
a) we act on our client's instructions and for the purposes they have specified;
b) the client remains responsible for having a lawful basis to collect that information and for its own privacy policy and consent mechanisms;
c) we do not use that information for our own purposes, and we do not add it to our own marketing lists; and
d) we return or delete it in accordance with our agreement with the client at the end of an engagement, subject to any legal retention obligation.
If you want to know how a particular brand handles your information, that brand's own privacy policy will apply, and you should contact them directly. We will help direct an enquiry to the right party if you contact us.
8. Multi-brand promotions
We sometimes coordinate promotions on behalf of more than one brand at once. Where entrant information is shared with several participating brands, we set that out clearly in the terms and conditions of the promotion and we obtain consent at the point of entry. Once information has been shared with a participating brand, that brand handles it independently and under its own privacy policy, and any request to access, correct or delete it must be directed to that brand as well as to us.
9. Who we disclose personal information to
We may disclose personal information to:
a) our clients, where the information relates to their campaigns or customers;
b) participating brands in a promotion, where you have consented at entry;
c) our service providers and technology platforms, including hosting, email marketing, advertising, analytics, project management, document storage, artificial intelligence assistants, accounting and payment providers;
d) professional advisers including lawyers, accountants and insurers;
e) a purchaser or prospective purchaser of our business; and
f) government agencies, regulators and law enforcement where required or authorised by law.
We do not sell personal information.
10. Overseas disclosure
Many of the platforms we use to deliver our services store or process personal information outside Australia.
Before disclosing personal information to an overseas recipient we take reasonable steps to ensure the recipient does not breach the APPs, unless an exception under APP 8.2 applies. By providing us with your personal information you acknowledge that overseas recipients may not be subject to privacy obligations equivalent to those in Australia, and that in some cases you may not be able to seek redress under the Privacy Act.
11. Direct marketing
Where we send marketing communications, we do so in accordance with the Privacy Act and the Spam Act 2003 (Cth).
Every commercial electronic message we send will identify the sender and include a functional unsubscribe facility. You can opt out at any time by using that facility or by contacting us using the details in section 17. We will action an opt out request within five business days.
If you ask us to tell you where we obtained your information, we will do so within a reasonable period unless it is impracticable or unreasonable to do so.
12. Cookies, analytics and advertising technology
Our website and the campaign websites we operate use cookies, pixels, tags and similar technologies to remember your preferences, measure how the site is used and deliver and measure advertising.
These technologies may be operated by third parties including GOOGLE, META AND ANY OTHERS, who may combine the information they collect with information they hold about you from other sources.
You can control cookies through your browser settings. Disabling cookies may affect how parts of our website work.
13. Security
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure. Those steps include access controls, multi-factor authentication on business systems, encrypted storage and transmission, staff training, and contractual obligations on our service providers.
No method of transmission or storage is completely secure. While we work to protect your information, we cannot guarantee absolute security.
14. Data breaches
If we become aware of unauthorised access to, unauthorised disclosure of, or loss of personal information that is likely to result in serious harm, we will assess it and, where the Notifiable Data Breaches scheme requires, notify affected individuals and the Office of the Australian Information Commissioner.
Where a breach affects information we hold on behalf of a client, we will notify that client promptly and work with them to determine who notifies affected individuals.
15. Retention
We keep personal information only for as long as we need it for the purposes described in this policy, or for as long as we are required to keep it by law. Financial records are generally retained for seven years. Campaign and competition data is retained for 180 days unless a client agreement requires otherwise. When information is no longer needed we destroy or de-identify it.
16. Access, correction and complaints
You can ask us for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 17.
We will respond within 30 days. We may ask you to verify your identity. There is no charge for making a request, although we may charge a reasonable fee for the cost of providing access. If we refuse a request we will give you written reasons and tell you how to complain.
If you are not satisfied with how we have handled your personal information or your request, contact our Privacy Officer in the first instance. If you are still not satisfied after we respond, you can complain to the Office of the Australian Information Commissioner at www.oaic.gov.au, by phone on 1300 363 992, or by post to GPO Box 5218, Sydney NSW 2001.
17. Contact us
Privacy Officer Devote Digital Pty Ltd 11/156 Boundary Street, West End QLD 4101
hello@devotedigital.com.au
18. Changes to this policy
We may update this policy from time to time. The current version will always be available and the date at the top shows when it was last changed. Material changes will be communicated to affected individuals where practicable.
