Fleet Space Technologies Pty Ltd ACN 607 948 729 (Fleet) takes your privacy seriously and is committed to responsible privacy practices.
Fleet seeks to comply with relevant laws, including the Privacy Act 1988 (Cth) (Privacy Act) and the EU General Data Protection Regulation (GDPR), where applicable.
This policy describes how Fleet manages your personal information including details of what types of personal information Fleet collects, how Fleet collects your personal information, the purposes for which Fleet uses your personal information and to whom your personal information is disclosed.
What is personal information?
In this policy “personal information” has the meaning set out in the Privacy Act. Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.
What types of personal information do we collect?
The types of personal information Fleet collects about you will depend on the purpose for which the information is collected. The types of personal information that Fleet may collect generally comprises names and contact details.
Fleet may also collect additional personal information such as employment history, date of birth and government related identifiers such as tax file numbers, with respect to contractors and prospective employees.
Fleet does not collect sensitive information.
Fleet also collects general analytics and other technical information (such as your IP address, device type, unique device identification numbers, browser type, version and language, operating system, geolocation data, browsing preferences, pages viewed while browsing the websites, page access times and referring website address and usage of Fleet's websites https://www.fleet.space/ and https://nebula.fleet.space (Websites) or products) arising from your use of the Websites.
This information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are on our Websites.
In addition to the types of personal information identified above, Fleet may collect personal information as otherwise permitted or required by law.
How do we collect personal information?
Fleet will usually collect your personal information directly from you, including when you:
· use or subscribe to the Websites or use Fleet's products or services;
· apply to work with Fleet or are engaged by Fleet as a contractor;
· make inquiries about us or our services or otherwise communicate with Fleet by email, by telephone, in person, via a website or otherwise.
In some cases Fleet may also collect personal information from third parties such as:
· publicly available sources;
· entities with which Fleet conducts business; and
· other third parties (for example, from referees if you apply for a position as an employee or contractor with us).
You may deal with us anonymously or using a pseudonym when you access many aspects of the Websites or making inquiries through the Websites or by telephone, if you do not require a response from us. However, to access Fleet's customer support features or for us to respond to inquiries, we require certain contact details from you. We generally need your personal information in order to transact with you.
We use "cookies" and similar tracking technology, such as web beacons and authentication tokens on our Websites. A "cookie" is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser, but not you.
Cookies can be "persistent" (cookies that stay on your browser until you delete them or else your browser deletes them based on the duration period set in the cookie) or "session" (cookies which are erased when you close your browser). Fleet uses session cookies and persistent cookies on the Websites.
If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our Websites, but it may impact your user experience of the Websites.
Such information does not refer to individuals by name or their contact details. We use this data in aggregate to improve our Websites and our goods and services. We may provide such aggregated data to third parties, but in so doing, we do not provide personal information without the individual's consent.
Why do we collect, use and disclose personal information?
In general Fleet collects, uses and discloses your personal information for purposes connected with its business operations.
Fleet will only collect, use, and disclose personal information about you if it has lawful basis to do so, for example:
· where you have given Fleet your consent;
· where processing of your personal information is necessary for the performance of a contract with you;
· to meet Fleet's legal obligations; and
· to pursue Fleet's legitimate business interests.
Fleet may use or disclose your personal information:
· for the purposes for which Fleet collected it (and related purposes which would be reasonably expected by you);
· for other purposes to which you have consented; and
· as otherwise authorised or required by law.
Some of the specific purposes for which Fleet collects, uses and discloses personal information are as follows:
· to provide its products and services to its customers or to receive goods or services from third parties;
· to enable the proper operation and functionality of its products and services;
· to improve its products and services;
· to verify your identity (for example, if you request access to the personal information Fleet holds about you);
· to consider you for a job at Fleet (whether as an employee or contractor) or other relationships with Fleet;
· to address any issues or complaints that Fleet has or you have regarding our relationship;
· to comply with its legal obligations;
· to develop and improve the quality of its Websites and products and customise its Websites and products according to your preferences, tailor search results, and show relevant advertising;
· for direct marketing purposes (see the "Direct marketing" section below); and
· to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
If Fleet is unable to collect your personal information then Fleet may not be able to provide you with the products, services and opportunities that depend on the collection of that information.
To whom do we disclose personal information?
Fleet may disclose your personal information to third parties in connection with the purposes described above.
This may include disclosing your personal information to the following types of third parties:
· its related companies;
· any potential third party acquirer of Fleet or its business or assets, and advisors to that third party;
· its professional advisers (such as lawyers, accountants or auditors) and insurers;
· its employees, contractors and third party service providers who assist Fleet in performing its functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers;
· organisations authorised by Fleet to conduct promotional, research or marketing activities;
· third parties to whom you have authorised Fleet to disclose your information (e.g. referees); and
· any other person as required or permitted by law.
If Fleet discloses your personal information to third parties it will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in Fleet's agreement with a third party service provider to which Fleet discloses your personal information.
Does personal information leave Australia?
Fleet stores personal information in servers located in Australia and in the Netherlands as well as through third party service providers located overseas, such as in the United States of America. Fleet may disclose your personal information to overseas recipients, such as to its subsidiaries, subscribers, resellers and service providers located overseas, in order to provide its products and services and to obtain services. Such overseas recipients may be located in different countries which are likely to include the Netherlands, the United States.
Except where an exception applies under the Privacy Act or other relevant legislation, Fleet will take reasonable steps to ensure that overseas recipients to whom Fleet discloses personal information do not breach the Australian Privacy Principles stated in the Privacy Act, and any other relevant legislation relating to privacy and data security, in relation to such information.
How do we protect your personal information?
Fleet engages service providers to store your personal information, including Amazon Web Services (AWS), Recurly, Autopilot and Google. Fleet recommends that you review these companies' privacy policies to understand how they use and store your personal information.
Fleet will take reasonable steps to keep any personal information it holds about you secure and to protect it from unauthorised access, modification or disclosure and from misuse, interference and loss. Among other techniques, Fleet usually:
· stores information behind its "firewall" in a secure location; and
· restricts the number of employees who can have access to such information.
However, you acknowledge that the security of personal information transmitted over the internet cannot be guaranteed. Fleet cannot guarantee that any personal information you disclose to Fleet will not become publicly available. Except to the extent liability cannot be excluded due to the operation of statute, Fleet excludes all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this policy restricts, excludes or modifies or purports to restrict, exclude or modify Fleet's obligations under the Privacy Act and any other applicable legislation or any statutory consumer rights you may have under any applicable law including the Competition and Consumer Act 2010 (Cth).
Please notify Fleet immediately if you become aware of any breach of security.
Fleet may use and disclose your personal information for the purpose of direct marketing to you if:
· you have consented to Fleet doing so; or
· it is otherwise permitted by law.
Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS. You can unsubscribe from Fleet's direct marketing, or change your contact preferences, by contacting Fleet (see the "How to contact us" section below) or by clicking on the relevant link at the bottom of any direct marketing emails.
How long do we keep your personal information?
Generally, Fleet will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this policy) unless a longer retention period is required by law.
This means that Fleet will store your personal information for the following periods:
· if you unsuccessfully apply for a job at Fleet (whether as an employee or contractor): up to 6 months;
· if you work at Fleet (whether as an employee or contractor): up to 6 years after you cease working with Fleet;
· if Fleet processes your personal information in connection with you being a supplier to Fleet (or an employee or contractor of a supplier) or in connection with you being a subscriber or reseller (or an employee or contractor of a subscriber or reseller): up to 6 years from your last interaction with Fleet; and
· if Fleet processes your personal information for direct marketing purposes or processes your personal information based on your consent, Fleet may process the information until you ask Fleet to stop and for a short period after that (to allow Fleet to implement your request). Fleet will indefinitely keep a record of the fact that you have asked Fleet not to send you direct marketing or to process your information so that Fleet can respect your request in future.
Fleet may retain your personal information for a longer period of time if it is reasonably necessary to comply with Fleet's legal obligations, resolve a dispute or maintain security.
When personal information is no longer required, Fleet will take reasonable steps to delete the personal information from Fleet's systems or de-identify the personal information.
How you can seek to access and correct personal information we hold about you
You may seek access to personal information Fleet holds about you by contacting Fleet as described in the "How to contact us" section below.
Fleet will provide access to that information in accordance with applicable legal requirements, subject to certain exemptions which may apply. Fleet may require that the person requesting access provide suitable identification and where permitted by law Fleet may charge a fee for giving access to your personal information.
If the personal information was provided to Fleet by any of Fleet's subscribers or resellers, Fleet may advise the relevant subscribers or resellers of your request and liaise with them about it.
If you become aware that any personal information Fleet holds about you is incorrect or if you wish to update your information, please contact Fleet as described in the "How to contact us" section below.
How you can complain about a privacy issue
You may make a privacy complaint in relation to personal information Fleet holds about you by contacting Fleet as described in the "How to contact us" section below.
If you make a privacy complaint, Fleet's Privacy Officer or another suitable staff member of Fleet will investigate the matter and attempt to resolve it as soon as reasonably possible (usually within 30 days of receipt of the complaint).
If you consider your concerns have not been resolved satisfactorily by Fleet, or you wish to obtain more information on privacy requirements you can contact:
· the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au; and
· if you are located in the European Union, your local data protection authority: https://edpb.europa.eu/about-edpb/board/members_en.
Individuals located in the EU
If you are located in the European Union, you may have the following rights:
· The right to access, rectify or update the personal information Fleet holds about you.
· The right to request erasure of personal information Fleet holds about you, for example if the personal information is no longer necessary to provide services to you.
· The right to require Fleet to stop using all or some of your personal information (for example, if Fleet no longer has a legal right to keep using it) or to restrict its use of your personal information (for example, if you consider that the personal information Fleet holds about you is inaccurate or if it is unlawfully held).
· The right to data portability. In some circumstances you have the right to be provided with a copy of the personal information Fleet has about you in a structured, machine-readable and commonly used format.
· The right to withdraw consent. You may withdraw your consent at any time where Fleet relied on your consent to process your personal information.
Fleet may ask you to provide suitable identification when you seek to exercise any of these rights.
Local exemptions and inconsistency with law
Where local laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption in Australia), Fleet may rely on such an exemption.
This policy will not apply to the extent that it is inconsistent with any applicable law.
Changes to this policy
Fleet may change this policy from time to time at its discretion. Amendments to this policy will be posted on the Websites. Your continued dealings with Fleet, for example use of its websites, products or services, will signify your agreement to this policy as amended.
How to contact us
If you have a query, concern or complaint about the manner in which your personal information has been collected or handled by Fleet or would like to request access to or correction of the personal information Fleet holds about you, please contact Fleet's Privacy Officer via email to firstname.lastname@example.org or by post to: Attn: Privacy Officer, Fleet Space Technologies, 8a Myer Court, Beverley SA 5009, Australia. If you are in the EU, and have a query, concern or complaint, or wish to access or correct your personal information, please contact email@example.com.
Updated on 28 June 2019