Apollo provides crowd funding [and recruitment] services (our “services”) including via our website at [insert website] (“website”).
What information do we collect?
We collect and hold Your Information, which may include your name, phone number, email, mailing address, date of birth, age, sex, gender, occupation, previous business experience, and other information relevant to the supply of our services that is collected by us or that you choose to provide to us.
If you make any transaction through our website or otherwise purchase services or products from us, we may also collect your bank or credit card details for payment and details of your credit history and creditworthiness.
A person under the age of 18 years (“Minor”) cannot use our services unless they are supervised by a parent or guardian and that parent or guardian acts on behalf of the relevant Minor. Accordingly we do not collect personal information from Minors and request that Minors do not submit such information to us.
How we collect Your Information
We collect Your Information as part of providing and offering our services to you. This includes when you provide Your Information to us by: (i) registering to use our website; (ii) completing any forms on our website or as otherwise required by us (including, without limitation, when you fill out an application to be a director of a company or subscribe for shares in a company);(iii) making any requests or transactions through our website or otherwise by using our services; (iv) communicating with us in person, during phone calls, by email, or otherwise via customer enquiries or communications.
Generally, we collect Your Information directly from you but we may also collect Your Information from other people or organisations if you have given your consent.
Why do we need Your Information?
We only collect or hold Your Information where it is reasonably necessary for our business functions or activities.
In particular, we need Your Information to:
- set up your account (if any) on our website and to keep that account secure;
- provide you with our services (including by analysing Your Information, providing Your Information to companies seeking crowdfunding or other service providers, and processing transactions);
- keep and update internal records;
- communicate with you about our services;
- create and update our databases and other records;
- ensure compliance with our contractual and other legal obligations to you; and
- administer our relationship with you by responding to your enquiries,
(the “Main Purposes”).
If you do not provide us with Your Information we may not be able to carry out some or all of the Main Purposes.
How do we use or disclose Your Information?
By submitting Your Information to us, you consent to us using or disclosing Your Information for:
- the Main Purposes;
- any purpose related to the Main Purposes that could be reasonably anticipated at the time Your Information was collected (“Secondary Purpose”);
- any purpose to which you otherwise consent (including as disclosed to you in an information collection statement at the point where we collect Your Information); and
- any other purpose required or authorised by law (including the Privacy Act).
Secondary Purposes may include: improving our services; sending you direct marketing about our services, deals and promotions; conducting customer surveys; managing our relationship with you; monitoring how you interact with us on our website or other contact points; or helping you to complete an activity that you have chosen to undertake.
We may use certain non-personally identifiable information (such as anonymous usage data, IP addresses, browser or platform type etc.) to improve the quality of our services, and to create new features, promotions, functionality and services by storing, tracking, analysing and processing user preferences and trends as well as user activity and communications.
[Note - is any personal information publicly disclosed on the Apollo website i.e. will a user of the site be identifiable to other users by their full name or other information]
Can you remain anonymous or use a pseudonym?
We will, if practicable, allow you to use a pseudonym or to not identify yourself (unless this is impractical or against the law (including the Privacy Act)).
In some instances, if you do not provide us with some of Your Information we may not be able to provide you with the relevant service, product or information. This may have an effect on whether we can begin or continue a relationship with you.
What disclosures do we make?
Generally speaking (and as described above under the heading “How do we use or disclose Your Information”) we will disclose Your Information for the Main Purposes. We may also disclose Your Information in other ways with your consent or to any other party where we are authorised or required to do so by law (including the Privacy Act).
We may disclose Your Information to our partners, suppliers, distributors and service providers in order to assist us in providing our services to you. Some of our service providers or the services they provide (like cloud storage services), may be based outside Australia, including in places like the United States of America. In order to protect Your Information, we take care where possible to work with service providers who we consider maintain acceptable standards of data security compliance, and we do our part to meet those standards as they apply to us. By providing us with Your Information, you consent to Your Information being used, stored and disclosed overseas (and acknowledge that no additional obligations that may apply to the overseas disclosure of personal information under the Privacy Act will apply).
Is Your Information confidential and secure?
We take all reasonable steps to keep Your Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may hold Your Information in both hard copy and electronic forms, but will store it in secure systems accessible only to authorised personnel.
Do we use “cookies”?
When you visit our website, the server may attach a "cookie" to your computer's memory. A “cookie” assists us to store information about how you use our website and to make assumptions about what information may be of most interest to you. This information is generally not linked to your identity. We may use knowledge of your user experience to better understand what products or services may be of interest to you and to collect statistical information.
Using other sites
Managing Your Information
You are responsible for ensuring that Your Information is accurate, current and complete and we encourage you to contact us to update Your Information if it changes at: [insert email address] or to [amend Your Information via your account on our website (if any)] [NOTE – please confirm, can users amend their personal information using their website account and if Users are responsible for any password associated with their account]
You may ask to access Your Information in accordance with the Privacy Act, including by asking us to provide you with a summary of Your Information that we hold subject to any limitations at law.
For your protection, we may require you to confirm your identity before access to Your Information is granted.
In most cases, we can provide you with a summary of Your Information free of charge. However, in some circumstances, reasonable costs may be charged to you in accessing Your Information in accordance with and subject to the Privacy Act or any other relevant law.
Queries and complaints
If you have a question or want to make a complaint about how we handle Your Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint). If we cannot resolve a complaint related to your privacy information, you may contact the Office of the Australian Information Commissioner (“OAIC”) directly.
We can be contacted via:
Or for more information about privacy issues in Australia and protecting your privacy, please visit the OAIC website at www.oaic.gov.au.
Last date Updated: [November 2017]