This Privacy Policy applies to all personal information collected by Sapher Group Holdings Pty Ltd ACN 673 297 044 and its related bodies corporate (we, us, and our) [including via our website located at www.sapher.com and from the provision of our software as-a-service products (our Services)].

We may modify or amend this Privacy Policy from time to time. We will publish any updated version of this Privacy Policy on our website.

Unless you notify us otherwise, we will assume that you have consented to the collection of all information which is provided to us, for use in accordance with this Privacy Policy.

1. What is personal information?

   1. The Privacy Act 1988 (Cth) currently defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
      1. whether the information or opinion is true or not; and
      2. whether the information or opinion is recorded in a material form or not
   2. If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this Privacy Policy.

2. What information do we collect?

   1. The kinds of personal information that we collect from you will depend on how you use [the website and our Services]. The personal information which we collect and hold about you may include: First name and email address.
   2. Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact us with a general enquiry, we will not ask for your name unless we need it to adequately handle your enquiry. However, for most of our functions and activities we usually need your first name and email address.

3. How we collect your personal information

   1. We collect personal information from you whenever you input such information into the website. Our web servers may automatically collect information when you visit our websites, including:
      1. the parts of our website you access during your visit; and
      2. your actions on our website.
   2. We also collect cookies from your computer which enable us to tell when you use the website and also to help customise your website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.

4. Purpose of collection

   1. The primary purpose for which we collect, hold, use and disclose your personal information is to provide you with our Services.
   2. We customarily disclose personal information only to our service providers who assist us in operating our website and providing the Services. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties. Where information is shared with these third parties, we will take all reasonable steps to ensure that third parties observe the confidential nature of such information and are prohibited from using any or all of this information beyond what is necessary to assist us.
   3. At this time, all third parties referred to above are located within Australia, however this may change in the future and if it does, we will update this privacy policy accordingly.
   4. We may also use your personal information for the purposes of direct marketing. By using our website and/or our Services, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature. You may also request not to receive direct marketing material from us by contacting us at [email protected]

5. How we hold your Personal Information

   We are committed to protecting your personal information. We take appropriate security measures to protect your personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of encryption by default, firewalls, monitoring of suspicious activity, data back up and recovery, and controlled site access.

6. Access and correction

   Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information, unless there is an exception under relevant privacy legislation. If you would like to obtain such access or correct your personal information, please contact us as set out below.

   For security reasons, we may require you to put your request in writing and to provide information that allows us to verify your identity. For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part (and we will let you know about this before actioning your request).

   If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).

   We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

7. Complaint procedure

   If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by our Executive Leadership Team and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at [email protected].

8. Overseas transfer

   Your personal information will not be disclosed to recipients outside Australia unless you expressly request us to do so. If you request us to transfer your personal information to an overseas recipient, the overseas recipient will not be required to comply with the Australian Privacy Principles and we will not be liable for any mishandling of your information in such circumstances.

9. How to contact us about privacy

   If you have any queries, or if you seek access to or correction of your personal information, or if you have a complaint about our privacy practices, you can contact us through our Chief Operating Officer at [email protected].