Privacy Policy

Last updated: March 2018

Impelus Limited ABN 24 089 805 416 (“IMS”, “we” or “us”) provides this privacy policy to explain how we collect, store, use and disclose personal information.This privacy policy (“Policy”) covers Impelus’ handling of two types of information:

  1. Information we receive about an individual (“individual”) who visits, uses and enters their personal information on our platforms, landing pages, websites and assets (collectively, the “Services”), on behalf of our Clients; and
  2. Information we receive directly from clients, business partners or prospective businesses (“Partners”) that visit and view this Site (www.impelus.com).

Collectively, Individuals and Partners are referred to as “You”, “Your”.

Applicability

This Privacy Policy applies to Impelus’ Services and other interactions (e.g. customer service inquiries, email information requests etc.).

By visiting our website, using any of our services, or otherwise providing us with personal information (or authorising it to be provided to us by someone else), you agree to personal information being handled as set out in this Privacy Policy. We may collect information about an individual from someone else, but we will take reasonable steps to ensure they are aware of the information collected and the circumstances of collection.

Anonymity

You may be able to deal with us without identifying themselves (i.e. anonymously or by using a pseudonym) when using our services. It is not mandatory to provide personal information, however if personal information is not provided that we need, Impelus may not be able to provide its services.

Cookies

Like most sites, we use technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices (referred to collectively as a “device”) that allow us to record information whenever you visit or interact with our sites or services. A cookie is a small piece of computer code that remains on your computer and contains information that helps us identify browsers and previous information viewed in relation to our services.

Cookie placement can be blocked by changing the settings on a browser. If cookies are not allowed, some (or all) of our website might not be accessible. 

Revisions to this Privacy Policy

We may update this Privacy Policy from time to time. Your continued use of our website, services or the provision of further personal information to us (directly or via an authorised person) after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.

Information We Collect and Recieve

We only collect, hold, and use personal information from individuals and partners where their consent has been obtained, for the purposes for which it was provided to us, where there is a justifiable business interest (such as to conduct business or fulfil a contractual obligation or agreement), or as permitted or required by law.

This may include:

  • sending information, offers, and promotions (“Offers”) about products and services that may be of interest, based on preferences selected by mail, phone/SMS/MMS or email;
  • fulfilling a contractual obligation or in the course of our business provided to our clients;
  • administering our database of personal information and maintenance of records;
  • enabling clients and advertisers an individual has selected and consented to communicate directly with them;
  • providing information to clients so they can send individuals “related or like” Offers that may be of interest; and
  • improving the quality of our Services.

In certain circumstances, we may be required or permitted by law or Court or Tribunal order to collect certain personal information about you.

Opting out and Individual’s Rights

  1. Individuals who sign up, register or leave their personal information may receive direct marketing.
  2. At any time, individuals can opt-out of receiving any Offers and information from us by clicking ‘Unsubscribe’ on the relevant Offer or communication, or emailing us at compliance@impelus.com.
  3. You can opt out of receiving any Offers and information from a third party to whom we provide your information directly at any time by clicking ‘Unsubscribe’ on their relevant Offer or communication,or emailing us at compliance@impelus.com.
  4. You may request a copy of all data that we may have collected and stored from you at any time by submitting a request in writing to compliance@impelus.com.
  5. You have the right for all your data to be deleted completely by submitting a request in writing to compliance@impelus.com. Exceptional instances are where a ‘reasonable expectation’ justifies a keeping the data for the purposes of suppression. In this scenario, we may be required to keep certain data (such as your email or phone number) in an offline suppression table, so that you do not receive any communications from us in future, thus satisfying your request.

What personal information is collected?

We generally collect personal information such as:

  • Your name;
  • Your contact details (eg address, email address, phone number);
  • Your date of birth;
  • Details about your interests;
  • Your lifestyle preferences;
  • Subjects about and persons from whom you may like to receive communications and information;
  • Your interactions and communications with us, including your participation in competitions, surveys, ad engagement and blog views.

How does Impelus Limited collect personal information?

We may collect your personal information in various ways, including via telephone, our website, email, or online forms.

Direct Collection

We collect personal information from you when you register to any of our services, when you opt into an Offer, or when you request further information from an Advertiser.

Indirect Collection

We may also collect information about you via technology, including cookies and other online identifiers such as your mobile device ID, from our websites when you visit.

On all occasions, personal information is collected, held, used and disclosed by us in accordance with this Privacy Policy.

How We Share and Disclose Personal Information

We disclose personal information to our clients and advertisers, third party agents, service providers, and contractors only for purposes consistent with the reasons for collecting the information set out in this Privacy Policy.

Some of the recipients of the personal information, including service providers that may be located in countries outside of Australia.   Before we disclose personal information to local or overseas recipients, we take reasonable steps to ensure they have privacy practices that meet the requirements of Australian privacy laws and this Privacy Policy.  Where applicable, our contracts with these parties will include an obligation for them to comply with Australian privacy law and this Privacy Policy. You consent to the disclosure of your personal information on that basis.

We may disclose personal information to any person or authority where we are required to by law.

Other than set out in our Privacy Policy, we will not disclose your personal information without your prior consent.

How We Protect Personal Information?

We are committed to ensuring security of personal information and take reasonable steps to protect any personal information we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. Impelus holds personal information electronically and in hard copy form, both on our own premises and with service providers, including the use of secure servers to store personal information.  In addition to ensuring all our third-party partners have reasonable controls that comply with relevant data protection laws in place to safeguard any data passed to them, we also implement the following security measures:

  • Security procedures for access to our business premises;
  • Security procedures within our offices;
  • IT security procedures including password protection, firewalls, and site monitoring.

However, data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information. You should notify us as soon as possible if you become aware of any security breaches. In turn, we will notify you of an eligible data breach involving your personal information in compliance with the Privacy Amendment (Notifiable Data Breaches) Act 2017 (the Act) where it has been deemed by us that such access or disclosure of said information would likely result in serious harm to you.

If we no longer need your personal information, we will take reasonable steps to destroy or de-identified it, although we may need to retain certain records to meet our legal requirements or meet a reasonable expectation, such as suppression.

We do not have control over information while in transit over the internet and cannot guarantee security of personal information during such transmission. Our website may include web links to other websites. We are not responsible for and do not endorse the content of those other websites or their privacy practices. We recommend you review the privacy policies of those websites.

What do you need to do if you have a complaint?

If you believe your privacy has been breached in any way, please contact us. To service you, we may ask you to provide us with sufficient details regarding your complaint, together with any supporting evidence.

We will investigate the issue and take reasonable steps  to resolve your complaint. Once your complaint has been resolved, we may keep the information pertaining to your complaint in our records for 24 months, unless you specifically request (in writing) complete deletion of all data collected about you. However doing so may result in us not being able to assist you in future as we’ll hold no record of you.

If you feel your complaint remains unresolved, you can write to the Office of the Australian Privacy Commissioner (www.oaic.gov.au).

Contact us

Impelus Limited
100 William Street East Sydney NSW 2011
E: compliance@impelus.com
P: +61 2 9360 3385

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