This document informs Users about the technologies that help this Application to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Application.
For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
This Application uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting the Owner.
Activities strictly necessary for the operation of this Application and delivery of the Service
This Application uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
Other activities involving the use of Trackers
This Application uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies and Usage Data.
How to manage preferences and provide or withdraw consent
There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.
It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.
Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
Locating Tracker Settings
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).
Consequences of denying consent
Users are free to decide whether or not to grant consent. However, please note that Trackers help this Application to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, in the absence of the User's consent, the Owner may be unable to provide related features.
Owner and Data Controller
Sendrato B.V. - Grasweg 67 - 1031 HX, Amsterdam - The Netherlands
Owner contact email: email@example.com
Since the use of third-party Trackers through this Application cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Application.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
1. PURPOSE OF OUR POLICY
(a) Providing the systems and services that we offer; and
(b) The normal day-to-day operations of our business, including compliance with AML and KYC regulations.
2. WHO AND WHAT THIS POLICY APPLIES TO
2.2 We handle Personal Information in our own right and also for and on behalf of our customers and users.
2.5 If an individual provides Personal Information or other information about someone other than themselves, they warrant that they have that person's consent to provide such information for the specified purpose.
2.6 Our website and services are unavailable to children (persons under the age of 18 years) without their parent or guardian’s consent.
3. THE INFORMATION WE COLLECT
3.1 In the course of business, we collect Personal Information necessary for our operations. This information allows us to identify individuals, share Personal Information when asked, contact individuals, and transact with them. The type of information we may collect includes but is not limited to:
(a) Personal Information, such as name, location, date of birth, nationality, family details, and other information defined as “Personal Information” in the Privacy Act;
(b) Contact Information, including email address, telephone & fax number, third-party usernames, residential, business, and postal address;
(c) Financial Information, such as bank or credit card details used for transactions;
(d) Statistical Information, for statistical purposes; and
(e) AML/KYC Information, required for compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations.
4. HOW INFORMATION IS COLLECTED
4.1 Most information will be collected when individuals use a smart wristband, make an inquiry, or interact with us in various ways.
(a) Registrations, Bookings, and Transactions. When individuals register or make a booking, they provide Personal Information details;
(b) Supply. When individuals supply goods or services to us;
(c) Contact. When individuals contact us in any way;
(d) Access. When individuals access us physically or through the internet; and/or
(e) Pixel Tags. Pixel tags enable us to send email messages in a readable format and track email opens.
4.2 We will ensure that individuals are aware of when their Personal Information is being collected, both electronically and physically.
4.3 Where we obtain Personal Information without an individual’s knowledge, we will either delete/destroy the information or inform the individual that we hold such information, following the Australian Privacy Principles.
5. WHEN PERSONAL INFORMATION IS USED & DISCLOSED
5.1 In general, we will not use Personal Information other than for the purpose for which it was collected, except with the individual’s permission.
5.2 We will retain Personal Information for the necessary period, unless a longer retention period is required or permitted by law.
5.3 If it is necessary to disclose an individual’s Personal Information to third parties compliant with the Australian Privacy Principles, we will inform the individual.
5.4 We will not disclose or sell Personal Information to unrelated third parties under any circumstances.
5.5 Information is used for purposes including:
(a) Providing goods and services;
(b) Verifying identity;
(c) Communicating with individuals;
(d) Investigating complaints or unlawful activity; and/or
(e) As required or permitted by law.
5.6 Some circumstances require us to disclose an individual’s information, such as legal obligations.
5.7 We will not disclose Personal Information to entities outside of Australia without similar privacy safeguards.
5.8 We may use third-party service providers (e.g., Gmail, MailChimp) for communication and contact storage, which may be located in the United States.
6. OPTING “IN” OR “OUT”
6.1 An individual may choose to have us collect their Personal Information or exclude themselves from some or all collection.
6.2 If an individual believes they received information from us without their consent, they should contact us.
7. THE SAFETY & SECURITY OF PERSONAL INFORMATION
7.2 We will take reasonable precautions to protect Personal Information from unauthorized access.
7.3 We use SSL encryption to store and transfer Personal Information, but online security cannot be guaranteed.
7.4 We are not responsible for the privacy or security practices of third parties.
7.5 Suspected misuse or unauthorized access to Personal Information should be reported.
7.6 We are not liable for losses resulting from authorized use of Personal Information.
8. Verification of Identity for AML/KYC Compliance
Disclosure for Verification
In accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and associated rules and regulations, Sendrato may be required to disclose your full name, residential address, and date of birth to a third-party service provider. This service provider may, in turn, provide this information to a credit reporting agency (CRA) to assess the accuracy of the identification information provided.
Document Verification Services
Additional verification processes may be conducted, which may involve your personal details being cross-verified with the document issuer or official record holder for further validation.
The CRA may compare the details you have provided with the personal information they hold (including names, residential addresses, and dates of birth of other individuals) for the purpose of verifying your identity.
Notification and Record-Keeping
The assessment will be provided to Sendrato, or its designated agent, solely for the purpose of identity verification. If we are unable to verify your identity using the information held by the CRA, we will notify you, providing the name of the CRA involved, and offer you the opportunity to update your information with the CRA. Records of the verification request will be maintained by both Sendrato and the CRA for a period of 7 years from the date of the request. You have the right to request access to these records.
9. HOW TO ACCESS AND/OR UPDATE INFORMATION
9.1 Users of Sendrato can update their Personal Information from within their Sendrato account or profile.
9.2 Subject to the Australian Privacy Principles, an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.
9.3 If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.
9.4 It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
9.5 We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.
10. COMPLAINTS AND DISPUTES
10.1 If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.
10.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
10.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
11. CONTACTING INDIVIDUALS
11.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions, and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
12. CONTACTING US
12.1 All correspondence with regards to privacy should be addressed to:
The Privacy Officer
Sendrato Australia Pty Ltd
You may contact the Privacy Officer by email in the first instance.
13. ADDITIONS TO THIS POLICY