This policy explains how Colleagues Systems Pty Ltd trading as Colleagues Matrixx (Colleagues Matrixx) processes Personal Data.  This policy may be amended or updated from time to time. Colleagues Matrixx adhere to the Australian Privacy Principles contained in the Australian Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).

This policy issued by Colleagues Matrixx is relevant to individuals outside our organisation we interact with, including customers, visitors to our office locations and server centers, users of our suite of software solutions (including Matrixx Exchange, Matrixx Portal and Matrixx Mobile), other users of our products or services, and visitors to our website/s.

Collection of Personal Data:

We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when that data is provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).

• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).

• Data you make public: We collect or obtain Personal Data that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

• Software data: We collect or obtain Personal Data when you download or use any of our Software Systems including the Matrixx Suite of Softwares.

• Website data: We collect or obtain Personal Data when you visit any of our webwebsites or use any features or resources available on or through a webite.

• Registration details: We collect or obtain Personal Data when you use, or register to use, any of our webwebsites, software, products, or services.

• Content and advertising information: If you interact with any third-party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third-party provider of that content or advertising.

• Third party information: We collect or obtain Personal Data from third parties who provide it to us in the usual course of business.

Creation of Personal Data

• We create Personal Data about you (e.g., records of your interactions with us).
• We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Websites, Software, products, or services, including where those data are collected from different devices.

Categories of Personal Data we Process

We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Websites and Software (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We may Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; national ID; passport details; and photograph.

• Demographic information: race; gender; date of birth / age; marital status, number of children; nationality; citizenship; salutation; title; and language preferences.

• Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.

• Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

• Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.

• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.

• Data relating to our Websites and Software: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.

• Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.

• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.

• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud).
• Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defense of legal rights; or
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providing our webwebsites, software, products, and services to you; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our webwebsites, software, products, and services; fraud prevention; and recruitment and job applications.

Disclosure of Personal Data to Third Parties

We disclose Personal Data to other entities within Colleagues Matrixx, for legitimate business purposes and the operation of our webwebsites, software, products, or services to you), in accordance with applicable law. In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
  • accountants, auditors, lawyers and other outside professional advisors to Colleagues Matrixx, subject to binding contractual obligations of confidentiality;
  • third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below;
  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
  • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties;
  • any relevant third-party acquirer(s), if we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation); and
  • any relevant third-party provider, where our Websites and our Software use third party advertising, plugins, or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to:

• only Process the Personal Data in accordance with our prior written instructions; and
• use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

International Transfer of Personal Data

“Colleagues Matrixx”, “we” or “us” means Colleagues Systems Pty Ltd trading as Colleagues Matrixx and our respective affiliates under the laws of Western Australia and Australia. Because of the international nature of our business, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk, and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

Data accuracy

We take every reasonable step to ensure that:

• your Personal Data that we Process is accurate and, where necessary, kept up to date; and
  • any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified without delay.

From time to time, we may ask you to confirm the accuracy of your Personal Data.

Data Minimisation

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

Data Retention

We take every reasonable step to ensure that your Personal Data is only retained for as long as needed in connection with a lawful purpose. We take every reasonable step to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy.

Your Legal Rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Websites, Software, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
  • the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
  • the right to request rectification of any inaccuracies in your Relevant Personal Data;
  • the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
  • where we Process your Relevant Personal Data based on your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Cookies and Similar Technologies

We Process Personal Data by using Cookies and similar technologies. When you visit a website or use our software, we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law.

We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

Terms of Use

Our TERMS OF USE govern all use of our Websites, our Software, and our services.

All use of our Websites, Software, products, or services is subject to our TERMS OF USE. We recommend that you review our Terms of Use regularly, to review any changes or updates we might make from time to time.

Direct Marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Websites, Software, products, or services that may be of interest to you.

If we provide Websites, Software, products, or services to you, we may send information to you regarding our Websites, Software, products, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

If you unsubscribe, we will not send you further promotional emails, but in some circumstances, we will continue to contact you to the extent necessary for the purposes of any Websites, Software, products, or services you have requested.

Contact Us

Colleagues Matrixx

2/1321 Hay Street

Subiaco  WA  6003

Australia

Email: security@colleaguesmatrixx.com.au

Matrixx Product Specific Privacy

Colleagues Systems built the Matrixx Suite of products as a series of SaaS business solutions. This SERVICE is provided by Colleagues Systems and is intended for use as is.

This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service.

If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions,

Information Collection and Use

For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to Username. The information that we request will be retained by us and used as described in this privacy policy.

For app based users, third party services may collect information used to identify you. (Apple / Google)

Google Play Services https://policies.google.com/privacy

Apple Privacy Policy https://www.apple.com/legal/privacy/en-ww/

Log Data

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilising our Service, the time and date of your use of the Service, and other statistics.

This Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

Service Providers

We may employ third-party companies and individuals due to the following reasons:

To facilitate our Service;

To provide the Service on our behalf;

To perform Service-related services; or

To assist us in analysing how our Service is used.

We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Children’s Privacy

These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us by emailing security@colleaguesmatrixx.com.au