Space Command Pty Ltd ACN 639 435 868 (referred to as "MODRON", "we", "us", "our") takes its responsibilities with respect to privacy seriously and is committed to handling personal information it collects for the purposes of setting up user accounts for this website (“Site”), your use of the Site to seek and engage in the provision of mediation services, or make use of other facilities or offers on the Site from time to time, in accordance with the Australian Privacy Principles ("APPs") and the Privacy Act 1988 (Cth) (the "Act").
What Personal Information does MODRON Collect and How Does it Collect it?
We collect personal information:
· directly from you;
· when you deal with us by telephone, letter or email;
· when you register on the Site or access and interact with the Site;
· when you place an order, subscribe to our newsletter, respond to a survey or fill out a form; or
· from other sources.
The type of information that MODRON collects and holds includes personal information about:
· individuals who use our services;
· your activities on the Site; and
· other people who come into contact with MODRON.
The information we collect may include information such as users’ names (or the names of their personnel or customers, as appropriate), mailing addresses, email addresses, telephone and/or facsimile numbers, dates of birth, postal addresses, credit card details,* and other transaction or registration details. We may also collect data that can, under certain circumstances, indirectly lead to personally identifiable information. Users who register to use the Site may choose to provide other information or related data in their profiles. You are aware of and consent to our use of such personal information to provide the services through the Site and to receive payments and to communicate that personal information to other Users with whom you engage through the Site, as well as to develop and maintain a record of dealing between us and you, your preferences and uses of the Site and to manage our relationship.
MODRON will generally collect this information by way of voluntary registration over the internet, by phone, facsimile and email, as well as feedback we may receive from our suppliers and contractors. Otherwise, MODRON will not collect or monitor any personal information about you without your consent.
When you visit the Site, we may record, for statistical purposes or in order to improve the Site or our service delivery, the following information:
· the date and time of your visit;
· web pages you have accessed;
· documents you have downloaded;
· your IP address; and
· the type of operating system and internet browser you use.
We also use Google Analytics which is a web analysis service provided by Google that tracks and reports the Site traffic. We use this information to improve our Website and customer service.
Where it is lawful or practicable to do so, we will provide you with the option of remaining anonymous in respect of transactions where that is appropriate, such as survey requests or service delivery or quality control information we may request.
How might MODRON use the Personal Information?
Generally, MODRON may use the personal information you provide or we otherwise obtain for the following purposes:
· to provide services and support to our customers;
· to respond to requests, inquiries or applications;
· to evaluate, develop and enhance the Site and our services;
· to resolve disputes and troubleshoot problems;
· to enforce the policies of our Website;
· to exercise any rights we have under contracts we enter into with you;
· to conduct website and system administration, such as for the technical support of our websites and computer systems;
· to provide information to users of our services that we think may be of interest to them; and
· to communicate special offers, promotions, newsletters, updates, service information or market research surveys.
If you would like to unsubscribe from receiving any newsletter and other such related emails from MODRON, you can click the unsubscribe button at the bottom of each newsletter email and follow the steps.
Otherwise MODRON will not use any personal information about you without your consent.
How might MODRON disclose the Information?
You authorise and consent to MODRON disclosing your personal information to:
· populate the required fields of any pages on the Site or in the course of provision of services through the Site or any other services we provide (such as updates or other information);
· enforce the policies of and rights under contracts with MODRON;
· protect the rights of any person;
· service providers such as organisations which provide data processing, printing and fulfilment operations;
· entities for whom we are acting as an agent or resupplier, such as our suppliers or related companies;
· any court, tribunal or regulatory authority as required by law, including in response to subpoenas, court orders, or legal process, or to establish or exercise our rights to defend against legal claims;
· any individual or authority if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law;
· anyone authorised by the individual the subject of particular personal information;
· another company, in the event that MODRON, the Site or a related asset or line of business is acquired by or transferred to that other company;
· any individual or authority to protect the rights, property or personal safety of any member of the public or MODRON.
· our employees, insurers, third party contractors, agents or to our sponsors on a confidential basis;
· our business partners, where from time to time we partner with other companies to provide co-sponsored or co-branded or services and may share your information with our co-sponsor;
· any trusted third party who assists in conducting our business, or servicing you, that agrees to keep your personal information confidential; and
· any other person or entity (the "Recipient") upon the basis that the Recipient may only collect, use or disclose the information for the purpose for which that information was originally collected by MODRON.
We will otherwise not transfer your personal information, or use, sell or disclose your personal information without your consent, unless:
· such disclosure is permitted under the Act;
· we are required by law to disclose that information;
· we are trying to protect against or prevent actual or potential fraud or unauthorised transactions; or
· we are investigating fraud which we believe may have already taken place.
The Website and/or other communications we make as part of or incidental to services we provide may contain links to websites which are owned or operated by third parties. You should make your own enquiries as to the privacy policies of these third parties. We are not responsible for information on, or the privacy practices of, such websites.
You consent to and authorise MODRON to transfer your personal information to an organisation or individual outside Australia. MODRON will only transfer personal information to a foreign country for the purpose of providing you with the services of MODRON and for carrying out any request you make when you use and interact with the Site (for example, if we outsource the platform or data storage to a cloud service provider).
Your personal information may be transferred overseas if you are accessing the Site from a country outside of Australia.
If MODRON sells all or part of its business or makes a sale or transfer of all or part of its assets or is otherwise involved in a merger or transfer of all or part of its business, MODRON may transfer your personal information to the party or parties involved in the transaction as part of that transaction.
MODRON will not otherwise disclose any personal information about you without your consent.
General Data Protection Regulation (GDPR) for the European Union (EU)
If you are based in the European Union while using the Site or MODRON’s services, we will process your personal information as a data processor on your behalf. In this case, you will be considered to be the data controller of the personal information as defined in Article 4(7) of the EU General Data Protection Regulation 2016/679 and the EU e-Privacy Directive (“Directive 2002/58/EC”).
If requested, we will execute the European Union Standard Contractual Clauses to facilitate the transfer of personal information to countries outside the European Union in accordance with Article 26(2) of the EU Data Protection Directive 95/46/EC.
Under no circumstances will MODRON be deemed a data controller with respect to any personal information under any relevant law or regulation.
Management and Security of Personal Information
MODRON takes reasonable steps to keep your personal information secure. We use a Verisign Secure Socket Layer (SSL) to encrypt all sensitive data transferred to and from your computer when making an online transaction. SSL is the industry standard for the transmission of credit card details. When looking at the url, if it starts with https:// that means all the information you enter will be in a secure and protected environment. After each transaction, your credit card details will not be stored on our server. Additionally, all transactions via the Site are managed through the STRIPE secure payments platform.
We cannot and do not guarantee that your personal information will be protected against unauthorised access or misuse or abuse. We do not accept any liability for the improper actions of unauthorised third parties.
In relation to the internet, while MODRON uses reasonable efforts to safeguard the privacy of your personal information, transmissions made by means of the internet cannot be made absolutely secure. MODRON assumes no responsibility for disclosure of data due to errors in transmission or by unauthorised third parties.
We retain the personal information we collect for as long as the information is relevant to our business purposes or the purpose of collection or until you request that we remove the data by contacting our Privacy Officer by email at email@example.com.
Personal Information about other people
The Website may allow users to share their personal information for the purpose of completing transactions. You agree to only use another user's personal information for the purpose of completing a transaction. MODRON encourages you to respect the privacy of other users. To best maintain the privacy of personal information, MODRON will only provide limited information regarding one user to another for the purpose of provision of services to the first user and requested by that user.
What happens if you choose not to provide the Information?
You are not obliged to give us your personal information. However, if you choose not to provide us with your personal information we may not be able to provide you with services offered by MODRON or to fulfil one or more other purposes for which your personal information is requested.
Sources of Information
The Website may collect information through the use of "cookies". Cookies are anonymous, unique alphanumeric identifiers sent to your browser from a website and stored on your computer's hard drive. The information we collect via cookies does not personally identify you, although it does identify your browser. We use this information to provide you with customised information when you visit the Site, and to collect aggregated user data for the purposes of usage analysis, quality control and administering and improving the Site. Aggregated data (which cannot be used to identify you) may be shared with third parties.
You can prevent your browser from accepting new cookies, be notified when you receive a new cookie, or disable cookies altogether by changing your browser's preferences menu. If you disable cookies, you may not be able to use the customised functions on the Site.
Updating your Personal Information
MODRON endeavours to ensure, but in no way guarantees, that the personal information it holds is accurate, complete and up-to-date. You will be able to update the information we hold about you through the “update your details” option under the “My Account” menu on the Site. You should promptly update your personal information if it changes or becomes inaccurate.
You can help keep your personal information up to date and secure by maintaining confidentiality of any password, user name, accounts and profiles used on the Site. In the event that you share your password or other personal information with others, you will be responsible for all actions taken on your account.
The term "sensitive information" refers to personal information about an individual's racial or ethnic origin, political or philosophical beliefs or affiliations, trade or professional affiliations, sexual preferences or practices or criminal record and health information.
We do not collect sensitive information unless it is volunteered by you.
Accessing Personal Information
You will generally be able to view the personal information we hold about you by accessing your account or profile information on the Site under the “My Account” menu.
MODRON will, on request, provide you with access to personal information held by MODRON about you, subject to any limitations or exceptions in the Act.
MODRON will deal with requests for access within a reasonable time. You must pay MODRON for reasonable costs incurred by MODRON in providing you with access.
If MODRON refuses to provide you with access to personal information about you, MODRON will provide you with reasons for the refusal, in accordance with the requirements of the Act
Security of your Personal Information
We will take all reasonable steps to protect the security of the personal information that we hold. This includes taking appropriate measures to protect electronic materials and materials stored and generated in hard copy. We also take reasonable steps to destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from unauthorised access, disclosure, loss, misuse and alteration.
Contacting our Privacy Officer