Cludo Pty Ltd (Cludo)
Your privacy is important to you and it is important to us. To help us deliver our services we collect, store and share a range of different data. We are committed to protecting your privacy and keeping your information safe.
This policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We encourage you to read this Policy carefully. This policy may be updated from time to time and you will be informed of any changes.
We are aligned with the National Privacy Principles (NPPs) contained in the Privacy Act 1988 (the Privacy Act). The NPPs governs the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. It is not intended to cover categories of personal information that are not covered by the Privacy Act.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Federal Privacy Commissioner at www.privacy.gov.au
It’s important to Cludo that you are informed about sharing your personal information with us.
What is personal information and why do we collect it?
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Some of the types of personal information we collect include:
- Information collected from visiting our Website (cookies etc.).
- Names, job titles, contact and address details
- Information in identification documents (for example, passport, driver’s license)
- Tax file numbers and other government-issued identification numbers
- Date of birth and gender
- Bank account details, and other financial information
- Educational qualifications, employment history and salary
- Personal information about your spouse and dependents
It may be necessary in some circumstances for Cludo to collect sensitive information. Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a professional body, criminal record or health information.
Sensitive information will be used by us only:
- With your consent; or where required or authorised by law
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
Holding personal information
“Personal information” is information about an individual and may include information that would allow us to identify an individual such as name, email address, telephone number, bank account details, taxation details, and accounting and financial information.
We take security measures to protect the personal information we hold including both physical (eg. security passes to enter our offices) and technology (eg. restriction of access, the use of encryption, passwords and digital certificates) measures.
We do not disclose personal information to third parties for them to send marketing material to you. However, we may share non-personal, de-identified or aggregated information to them for research or promotional purposes.
Cludo does hold some personal information in hard copy and electronic formats.
Disclosure of personal information
Depending on the nature of the engagement or circumstances of collection, we may disclose your personal information to our employees to fulfil the purpose for which the personal information was collected, or a related or ancillary purpose or otherwise in accordance with the Privacy Act. The countries to which such disclosures are made, and types of personal information disclosed, depend on the specific circumstances of the engagement. This may include, but is not limited to, independent contractors and consultants, information technology providers, credit managers and debt collecting agencies.
We require our service providers to adhere to our privacy guidelines and not to keep, use or disclose personal information we provide to them for any unauthorised purposes.
How we store and protect your data
Cludo data and information is held in Australia, the United States of America and Japan on Salesforce.com infrastructure, but we do advocate the use of some third-party applications and service providers to assist the provision of our services. The servers of these third-party providers are commonly located in the United States of America.
Cludo’s Information Security Self-Assessment Checklist Or ISSAC, safeguards Cludo and our customer’s data against theft or manipulation, by continuously monitoring behaviours and compliance to IT and Information Security policies.
- Monitors employee behaviours and compliance to access and usage policies
- Educates and assesses Cludo employees understanding
- Performs physical checks of employee work stations, email accounts and shared drives
- Performs checks of physical security mechanisms such as access systems and cameras
- Assesses and identifies risk areas
Cludo is committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. With third party providers we ensure that your personal information is stored on secure servers that have SSL Certificates issued by leading certificate authorities and all data transferred between you and the Service is encrypted.
You can always choose not to provide your personal information to Cludo, but it may mean that we are unable to provide you with the service.
Cludo only discloses your personal information in limited circumstances
Cludo uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations (including internal business requirements, such as recruitment and human capital requirements). This means that individuals and organisations outside of Cludo will sometimes have access to personal information held by Cludo and may collect or use it from or on behalf of Cludo.
Cludo does not routinely disclose personal information to other organisations unless:
Use or disclosure is permitted by this policy;
- We believe it is necessary to provide you with a product or service which you have requested (or, in the case of a partner, employee or contractor of Cludo, it is necessary for maintaining or related to your role at Cludo);
- To protect the rights, property or personal safety of any member of the public or a customer of Cludo or the interests of Cludo;
- Some or all of the assets or operations of Cludo are or may be transferred to another party as part of the sale of some or all of Cludo’s business;
- You give your consent; or
- Such disclosure is otherwise required or permitted by law, regulation, rule or professional standard.
If for some reason you believe we have failed to adhere to our principles on privacy and data security, please notify us by email at info@Cludo.com and we will investigate to determine and correct the problem promptly.
You can request access to your personal information, subject to some limited exceptions permitted or required by law.
Such request must be made in writing to Cludo and we may charge reasonable costs for providing you access to your personal information.
Requests should be addressed to:
Cludo Pty Ltd
Suite 1, Level 3
340 Adelaide Street
Brisbane QLD 4000
Please allow 10 business days for your request to be processed.