Privacy Policy

PRIVACY POLICY

Potentiality Pty Ltd, Potentiality UK and other companies within our group ("Potentiality", "We", "Us" or "Our") respect the privacy of Our client organisations (“Clients”) and every person who uses Our Online Communities (“you”, “your” or a “user”). This Privacy Policy governs the way in which We use and disclose personal information ("Personal Information") held on Our Online Communities. Personal Information includes any information that identifies you personally, such as your name, address or email address.

Potentiality will process your Personal Information at all times in accordance with all applicable data protection and privacy laws.

We do not transfer Personal Information outside a Client’s jurisdiction or to third parties except as permitted in accordance with applicable data protection and privacy laws.

We may provide additional privacy information in connection with a particular Potentiality product or service. Such information prevails over this Policy to the extent of any conflict.

By using Our Online Communities and/or by submitting Personal Information to Potentiality, you agree to the processing of your Personal Information in the manner provided in this Policy. If you do not agree with this Policy, please do not use Our Online Communities or provide Us with your Personal Information.

Please see Our Privacy Collection Notice for further details of how We use, collect and disclose personal information about you

A. Use of Personal Information

We use the Personal Information We collect in the following ways:

  • to allow registration on Our Online Communities;
  • to maintain security protocols such as passwords and user logins;
  • to carry out Our contractual obligations with users and Clients;
  • to enable use of any services that We may from time to time provide through Our Online Communities; and
  • for general administration of Our Online Communities, including the hosting of data with Amazon Web Services (please visit www.aws.amazon.com/compliance for further details)
We will retain your Personal Information for as long as it is relevant to Our legitimate business purposes or until you request that We remove the data (see Part J below).

B. Collection of Personal Information

Your Personal Information is collected in three main ways:

C. Disclosure of Personal Information

We may disclose your Personal Information to third parties in the following circumstances:

  • if We are under a legal obligation or entitlement to do so;
  • to enforce or apply a contract with you, a Client, to a group company or otherwise with your consent;
  • to detect fraud or unauthorised access;
  • to protect Our rights, property, or safety, or that of others; or
  • pursuant to a sale, merger, assignment, joint venture or other transfer or disposition of a portion or all of the assets of Potentiality.

We will not disclose personal information to overseas entities except as permitted above

D. Cookies

What are “cookies”?
Cookies contain information that is transferred to your computer's hard drive. They help Us to improve Our Online Communities and to deliver a better and more personalised service.

Can I refuse to accept cookies?

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. Unless you have adjusted your browser setting so that it will refuse cookies, Our system will issue cookies when you access Our Online Communities.

What cookies do We use on Our Online Communities?

We make use of the following cookies:

  1. Google Analytics: This tracks the pages that a user views and sends information to Google Analytics so that We can understand what information is useful to users. This cookie does not collect Personal Information.
  2. ASP.net: A standard cookie placed by Microsoft’s .net framework in order for it to function correctly.
  3. Login tracker: This tracks whether you are currently logged in to the Online Community, and is only activated if you click the “remember me” tick box.

We do not use cookies to provide marketing information to third parties.

E. Security

We will protect the security of your Personal Information and honour your choices for its intended use. We carefully protect your Personal Information from loss, misuse, unauthorised access or disclosure, alteration, or destruction, including by:

  • using advanced firewall technology and physical storage of data within secure data centres (located in the jurisdiction appropriate to the relevant Client);
  • using electronic security systems;
  • limiting access; and
  • Use of confidentiality agreements.

Unfortunately, due to the nature of the Internet We cannot guarantee that your Personal Information will be protected against unauthorised access, loss, misuse, or alterations.

F. Account Security

Your password is the key to protection of your Personal Information. Use unique numbers, letters and special characters, and do not disclose your password or user name to anyone. If you do share your password or user name with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify Us and change your password.

G. Hyperlinks to other websites

Our Online Communities contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and We urge you to review them. They will govern the use of Personal Information you submit whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

H. Your right of access

You have the right to access and update your Personal Information or to require its deletion. We endeavour to ensure that Personal Information is up-to-date, accurate, and complete. If you wish to access, delete or correct your Personal Information, please contact Us as set out in Part J below and your requests will be dealt with in a prompt and proper manner. No charge will be levied for complying with a correction request, however, for all other requests We may charge a small fee to cover Our costs. Requests to delete Personal Information will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on Us.

I. Changes to this Privacy Policy

From time to time We may make reasonable changes to this Privacy Policy, for example where required by law, regulation or Our business model. When We do We will publish the changes on Our Online Communities. If you do not agree to such changes, please do not continue to use Our Online Communities.

J. Enquiries and Complaints

You can make enquiries, requests to access/delete or correct your information, or complain about alleged breaches of privacy to Our Privacy Officer:

Asia Pacific
Privacy Officer
Potentiality Pty Ltd
privacyofficer@ptly.com
272 Dorcas Street, South Melbourne,Victoria 3205, Australia

Europe
Privacy Officer
Potentiality UK Ltd
privacyofficer@ptly.com
31 Severn House, 19 Enterprise Way, London SW18 1GD

We aim to acknowledge receipt of requests within 10 working days, and aim to resolve all complaints within 30 working days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, We will respond to your complaint in a reasonable time. If you are not satisfied with Our response to your complaint, you can contact the Privacy Commissioner in your jurisdiction.

 

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