Last modified: 31st July 2018
Who We Are
Branch Up Pty Ltd (hereafter ‘we’ or ‘us’ or ‘our’) respects the privacy of the users of its website. To provide and improve our services, we may occasionally collect and process data that can reasonably identify you as a natural person. We have therefore put this Privacy in place to explain that Branch Up processes personal data in a fair and transparent manner and in compliance with the relevant data protection Regulation and laws. This Policy also informs you of your rights and particular choices you can make in respect of personal data we process about you. This policy also outlines lawful grounds that we may rely on in processing your data including circumstances where we may process your personal data without express consent. Please read this policy carefully. By continuing to use or access the site, you signify that you have read and understood and our data processing activities.
Information That We Collect
The personal data that we collect from you:
- Full Name
- Personal or business email
- Company name
Branch Up collects personal data in different ways. We collect information that you provide to us, information we receive automatically when you access the site and information which may be supplied to us by third parties.
Information you provide: Our website provides you with the ability to contact us directly. Please note that when you contact us directly, we may require you to provide certain personal data including for example your name, e-mail, company name and/or country of residence. If you contact us by email, you may also be providing certain personal data and we advise you to exercise caution when doing so. If you place an order for products or services, we may collect your name and contact information to fulfill your orders.
Information we collect automatically via server logs and other technologies. If you access our website, our systems may automatically log certain information about your interaction with the site. This may include your Internet protocol address, device type and operating system, and browser data (browser type and version, preferred language, add-ons, extensions or cookie preferences) as well as specific pages viewed on the site. We also use third party services like Google Analytics to monitor user interaction with our website. Google Analytics may collect and disclose to us certain data about your interaction with the site. This data may include online identifiers (such as internet protocol address, cookies, client and user id), page views, click stream, time spent on the site, as well as the website that referred you to the resource of content on our website. Where online identifiers may be used to reasonably identify you as an individual, we will process that data on the basis of your consent. Please read more about Google Analytics below.
How We Use Your Personal Data
Branch Up takes your privacy seriously. We will use personal data only for the specific purpose(s) for which that data was obtained and in compliance with the European Union General Data Protection Regulation (GDPR). Branch Up will be collecting and using your personal data so as to:
- Process your online orders and provide any information, products or services requested by you.
- Create and customise products or services ordered by you.
- Improve our website and services.
We must have a legal basis for processing such personal data outlined above, and there are six lawful bases under the GDPR:
- Consent: Personal data may be processed if the individual has given express consent for processing data for a specific purpose;
- Contract: personal data may be processed so as to perform obligations under a contract between the individual and Data Controller or where the individual asks the Data Controller to perform certain measures before an agreement is reached;
- Legal Obligation: Personal data may be processed as required to comply with any legal obligation;
- Vital Interest: Personal data may be processed to protect someone’s life;
- Legitimate Interest: Personal data may be processed in pursuit of Data Controller’s legitimate interests or the legitimate of a third party provided that the legitimate interest do not impair on the data subject’s rights and freedoms.
We will be processing your personal data under the following lawful bases:
- Consent: We rely on your consent to process data so as to provide our products and services.
- Performance of contractual obligations: We will collect your personal data as necessary to fulfil our contractual obligations under any agreement between you and Branch Up and to ensure that relevant order and transaction information is sent to your preferred communication channel (email or mailing address.)
- Compliance with legal obligation: We will collect and, in accordance with our data retention policy, store your personal data if we are required to do so for tax and accounting purposes including for example payment of Value Added Tax or Goods and Services Tax.
- Legitimate Interests: We will regularly collect and use anonymized website usage data as part of our legitimate interest to improve our website and services. Website usage data that contain personal identifiers will not be collected. We may also send you marketing and promotional information which we believe would be useful to you and in our interests.
If you are a resident of the EU/EEA, you, as a data subject, have the following rights in accordance with the GDPR:
- You have the right to access any personal information that Branch Up processes about you and to request a free copy of information about what personal data we hold about you. Please note we are permitted by law to charge a reasonable fee for administrate costs for additional copies and/or to decline access requests if they are patently excessive or unreasonable.
- Right to rectification. If you believe that personal data we hold about you is incomplete, outdated or inaccurate, you have the right to ask us to rectify, complete or update that data
- Right to be forgotten. You also have the right to request erasure of your personal data
- Right to restrict processing of personal data in accordance with the data protection laws, for example where processing is illegal or unlawful.
- Right to data portability. Where applicable, you have the right to permit the transfer of your personal data to one or several service providers providing services to you.
Sharing and Disclosing Your Personal Information
Branch Up uses Google Analytics to understand how users interact with our site and improve its functionality. Please note that Google Analytics is a third party service acting on our behalf. In this case Google is our data processor. Google has implemented measures to comply with the GDPR and other protection laws including IP anonymization, and signing a data processing agreement with us as the data controller. Google has developed a Google Analytics opt-out browser extension. If you want to opt-out of Google Analytics usage data tracking, please download it and install on your browser.
Google Analytics is web analytics software developed by Google. Google Analytics may set and use tracking cookies (cookie identifier) to monitor how users interact with our website. The data collected by Google Analytics may include internet protocol address (which will be transmitted and stored in Google servers), geolocation data, page views, bounce rate, website load time, and server connection and response information. Google uses data from Google Analytics to: measure how web traffic arrives to our site and understand which traffic converts to sales; evaluate how users interact with Branch Up (including for example, page views, average time on the site, and/or clicks on call to actions on the site; measure the effectives of the site content; compile and supply to us analytical reports on website usage. We use data shared to us by Google to improve our services, optimize content, and to show you ads based on you interaction with our website. Please note that Google does not combine data categories to identify you. To prevent personal data from being sent to Google Analytics, we have enabled the IP anonymization feature of Google Analytics. This feature will anonymize online identifiers (IP address, user ID, ect.) which are considered personal data under the GDPR. If we use Google Analytics to set tracking cookies and collect online identifiers, we will provide you with the mechanism to opt-out of one or several ways of our use of Google Analytics.
Protecting personal data
Branch Up takes every reasonable effort and care to protect your information from unauthorised access, alteration, disclosure or destruction. In this regard we have implemented technical and organisational measures including: encryption of data before being transmitted over the internet, pseudonymisation of personal data identifiers as well as regular malware scanning.
Transfers Outside the EU
Branch Up uses certain third party services that may be hosted outside of the EU (for example Google servers). These services may collect and transfer of personal data submitted by you through the site outside the European Economic Area (“EEA”) for the purpose of web analytics and email marketing. Please note therefore that when you use the site, certain personal information may be processed on servers which are located outside of EU. In these cases, we will ensure that the providers we work with implement adequate level of protection for your data and comply with by data processing agreements and procedures set out by Branch Up to protect your data and comply with the applicable data protection laws.
Consequences of Not Providing Your Data
Please note that you have the choice not to provide any personal data or consent for the use of such data. If we must obtain consent for the use of your data in order to provide services or supply products and/or information to you, we will not perform such services or supply product and information, as the case may be, until your consent is given for that purpose.
As we have indicated in the ‘How We Use Your Personal Data’ section of this Policy, we may from time to time process your personal data under the legitimate interests’ legal ground. If we do, we must beforehand undertake an in-depth assessment of the particular legitimate interests so as to strike a balance between the pursuit of our interests and the risk posed to your rights and freedoms by this particular kind of processing.
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