Who we are
The website and its content is owned by WebRefresh (NSW) ABN: 32 969 627 323 (“Company”, “we”, or “us”). The term “you” refers to the user or viewer of www.webrefresh.co (“Website”). If you want to know more about what we do, you can visit the Team page on our Website at http://webrefresh.co/our-team/
Our principles of data protection
Transparency: We are committed to being open, honest and transparent about Personal Data.
Trust: We agree to only use Personal Data for the purposes we say we will, and for improving the effectiveness and efficiency of our services.
Safety: We are committed to keeping Personal Data provided to us secure.
Responsibility: We accept the responsibility of handling Personal Data.
What information do we collect?
When you visit our Website or use our services, we collect Personal Data.
The type of personal information we collect will depend on the circumstances of its collection and the nature of your dealing with us. This information may include your name, contact details, date of birth, job title, employment history, credit and financial details, bank account details, information relevant to providing you legal services and preferences and opinion about our services. This is not an exhaustive list.
Sensitive information includes information about an individual’s mental health, disability, racial or ethnic origin, criminal convictions, religious affiliation and political affiliation. We will only collect, use or disclose your sensitive information if it is reasonably necessary to carry out our functions or activities and we have your explicit consent.
The ways we collect your data are as follows:
Information you provide to us directly: When you visit or use some parts of our Website and/or services we might ask you to provide Personal Data to us when you complete a contact form, respond to an email offer or to receive a newsletter, participate with us on social media forums or when ordering or registering on our site, as appropriate, you may be asked to enter your name, e-mail address, mailing address and/or phone number.
By doing so you are giving this information to us voluntarily, and by providing us with this information you are giving us consent to use, collect and process this Personal Data. If at any time you wish to opt out or request us to delete your Personal Data you can contact us at email@example.com
Information we collect automatically: We collect some information about you automatically when you visit our Website or use our services, like your IP address, device ID, computer and connection information, geolocation information and device type. We also collect information when you navigate through our Website and services, including what pages you looked at and what links you clicked on. This information gives us get a better understanding of how you’re using our Website and services so that we can continue to provide the best experience possible, for example by personalising the content you see
We do not set any personally identifiable information in cookies, nor do we employ any data-capture mechanisms on our Website other than cookies. If you prefer, you can choose to disable cookies through your own web browser’s settings or have your computer warn you each time a cookie being sent. Please note disabling this function may cause some of the features on this Website not to work as well as intended however you can still place orders for our programs or services over the telephone.
Information we get from third parties: At times we might collect Personal Data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the Personal Data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.
Where we collect Personal Data, we’ll only process it to perform a contract with you, or where we have legitimate interests to process the Personal Data and they’re not overridden by your rights, or in accordance with a legal obligation, or where we have provided your consent.
If we don’t collect your Personal Data, we may be unable to provide you with all our services, and some functions and features on our Website may not be available to you.
How we hold your personal information
We hold your personal information in encrypted electronic forms, and in secure databases or cloud-based platforms that we own and operate or that are owned and operated by our service providers. While we take reasonable steps to protect the security of your personal information, data protection and security measures can never be guaranteed. We therefore cannot guarantee the security of your personal information.
What do we use your information for?
We mostly use your Personal Data to operate our website and provide you with any services you’ve requested, and to manage our relationship with you. We also use your Personal Data in the following ways:
To communicate with you: We may provide you with information you’ve requested from us or information we are required to send to you and to respond to your enquiries, comments, and applications.
We may communicate with you about changes to our websites and services, security updates, or for assistance with using our website and services.
We may communicate about and administer our products, services, events, online webinars, podcasts, programs and promotions (such as by sending transactional emails about your purchases).
We may send you marketing materials we think you may be legitimately interested in or ask you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
To personalize your experience: Your information helps us to better respond to your individual needs.
To enhance our websites and services and develop new ones: By carrying out technical analysis or the tracking and monitoring of the use of our website and services, we can improve and optimise your user experience.
To support you and improve customer service: Your information helps us to more effectively respond to your customer service requests and support needs.
To administer a contest, promotion, survey or other site feature
To protect you: So that we can make sure everyone is using our Website in accordance with our permitted uses, and so we can detect and prevent any fraudulent or malicious activity.
To market to you: In addition to marketing communications, we may also use your Personal Data to display targeted advertising to you online. Through our own website, through third party websites or through social media platforms, we carry out profiling activities in order to learn more about you and offer you tailored advertising based on your behavior on our platforms. You can opt out of Google Analytics at any time. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
To analyse, aggregate and report: We may use the Personal Data we collect about you and other users of our website and services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.
To send periodic emails: The email address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
The legal basis for processing your Personal Data as described above will typically be one of the following:
Performance of a contract with you or a relevant party;
Our legitimate business interests; or
Compliance with our legal obligations.
Security: How do we protect your information?
Security is a priority when it comes to your Personal Data. We are committed to protecting your Personal Data and will take all commercially reasonable steps to protect the Personal Data you provide to us from misuse, disclosure or unauthorised access.
However, we cannot guarantee that your Personal Data will always be secure due to technology or security breaches. If we become aware of a high-risk data breach, we will notify you (and the appropriate authority) within 72 hours.
How we can share your data
We may share your Personal Data with third parties who we trust and who we are affiliated with. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. For example, third party service providers and partners who assist us with the functionality of the Website or services, or to deliver, market or promote our goods and services to you.
We use third-party browser and mobile analytics services like Google Analytics® on the Website. These services use tools to help us analyse your use of our Website including information like the third-party website you arrive from, how often you visit, events within the Platforms, usage and performance data, and purchasing behaviour. We use this data to improve the Website and provide information, products and services that may be of interest to you.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We may be required to provide your Personal Data to regulators, law enforcement bodies, government agencies, courts or other third parties where it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure.
Your Personal Data may be shared with an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business.
We will only disclose your Personal Data to other third parties where we have obtained your consent.
Direct marketing means using your personal information to contact you via the phone, SMS or email to promote our services. You acknowledge that by providing us with your personal information, we, our related entities or business partners may contact you to promote and market our respective products and services. You can opt-out from being contacted by us, our related entities or business partners for direct marketing by emailing us at firstname.lastname@example.org at any time and asking to be unsubscribed.
Data Controller and Data Processors
We are the data controllers as we are collecting and using your Personal Data. We use trusted third parties as our data processors for technical and organisational purposes, including for payments and email marketing. We make all reasonable efforts ensure our data processors are GDPR- compliant.
International Data Transfers
In order for us to provide the products and services to you, your Personal Data will be stored and processed in Australia. By providing us with your personal information, you consent to us disclosing your Personal Data to third parties located overseas and acknowledge Australian Privacy Principle APP 8.1 does not apply to any such disclosure. When we share data (to the extent that we do from time to time), it may be transferred to, and processed in countries other than the country you live.
Where data is shared with third-party data processor in other countries, we put reasonable safeguards in place to ensure your Personal Data remains protected however we note that your Personal Data will be captured, transferred, stored and processed in accordance with their policies, practices and in compliance with their local regulatory laws. For those in the European Union (EU), this means that your data may be transferred outside of the EU. Where your Personal Data is transferred outside the EU, it will only be transferred to countries that have been identified as providing adequate protection for EU data or to a third party where we have approved transfer mechanisms in place to protect your Personal Data.
We will always provide you with the ability to opt-out of our communications by selecting the unsubscribe link at the bottom of all e-mails. We will not share your email address without your consent.
Third Party Websites
We may link to other websites on our Website. We have no responsibility or liability for the content and activities of any other individual, company or entity whose website or materials may be linked to our Website or its content, and thus we cannot be held liable for the privacy of the information on their website or that you voluntarily share with their website. Please review their privacy policies for guidelines as to how they respectively store, use and protect the privacy of your Personal Data.
Children’s Online Privacy Protection Act Compliance and Minors
We do not collect any information from anyone under 16 years of age in compliance with COPPA (Children’s Online Privacy Protection Act), the Australian Privacy Act 1988 (Clth) and the GDPR (General Data Protection Regulation of the EU).
We’ll retain your Personal Data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or is converted to aggregate data.
You have the right to ask us not to send you marketing emails at any time by sending your request to email@example.comYou can also just follow the unsubscribe instructions contained in the marketing communication.
You have the right to know what Personal Data we hold about you, and to make sure it’s correct and up to date.
You have the right to request a copy of your Personal Data or ask us to restrict processing your personal data or delete it.
You have the right to object to our processing of your Personal Data.
You have the right to “be forgotten” and request we erase your Personal Data.
You can exercise these rights at any time by sending an email to us at [insert email address] which we will respond to within 30 days.
If you wish to contact us about what personal data we hold about you or you have a question or feedback for us on this notice, our websites or services, you can contact us at anytime at firstname.lastname@example.org
If wish to make a complaint you can email us at email@example.com We will review and investigate your complaint and get back to you.
You can also submit a complaint to the Privacy Commissioner or local authorities, which will advise you how to submit a formal complaint.
41/12-14 Waratah St
Mona Vale, NSW, 2103