SNA TOOLBOX PRIVACY POLICY
SNA Toolbox Pty Ltd (ACN 615 827 999) (“we”, “us” or “our”) provides online survey data collection, analysis and reporting services as part of the SNA Toolbox software platform. This document (“Privacy Policy”) sets out how we collect, use, process, store, share and disclose the Personal Information of individuals who interact with us – including Authorised Users operating programs using our services and the Participants in such programs (“Users”).
We are committed to protecting your privacy and respecting and upholding your privacy rights under the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (Privacy Laws). We take all necessary and reasonable steps to comply with the relevant Privacy Laws and to deal with inquiries or complaints from individuals about compliance with the relevant Privacy Laws.
If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact the SNA Toolbox Privacy Coordinator via the notice details set out in Section 13 below.
1. Your Information
We refer to “you” a lot in this Privacy Policy. To better understand what information is most relevant to you, see the following definitions of types of Users:
“Authorised Users”: You hold a registered account with us and you either directly create surveys, monitor data collection processes, or create data visualisations and reports or you are collaborating on, commenting on, or reviewing surveys, data collection processes, data visualisations or reports within an account.
“Participants”: You participate in one of our surveys and we collect the information about you that you provide in the survey.
“Users” includes Authorised Users and Participants.
We will collect Personal Information only by lawful and fair means and not in an unreasonably intrusive way. We collect Personal Information directly from you to the extent necessary to provide our services of online survey data collection, analysis and reporting services and as required by the Privacy Laws. We may also collect Personal Information from you when you fill in an application form, communicate with us, visit our website, provide us with feedback, or complete online surveys.
We have an obligation to take reasonable steps to ensure personal information we hold is correct, accurate and up to date. For this reason, we expect you to provide accurate, up to date and complete Personal Information at the time it is collected.
2. Information about children under 18
When our Services involve Personal Information about Participants who are under 18 years old, SNA Toolbox has the following mechanisms in place to protect children’s privacy.
We require Authorised Users to be at least 18 years of age to hold a registered account to access our Site and Services and to operate any programs using our services.
Participants under 18 years of age are only allowed to participate in surveys conducted by an Authorised User, when the relevant Authorised User has:
notified the Participants of the details of the program and has the authority and/or sought the Participants’ consent to collection and disclosure to SNA Toolbox;
provided sufficient information and evidence to demonstrate that any Personal Information collected from such Participants has been collected in accordance with all applicable Privacy Laws.
3. Information we may collect about you
Personal information is any information relating to an identified or identifiable individual (“Personal Information”). An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
The type of Personal Information we collect from you may include, without limitation, the following:
full name;
address;
email address;
telephone number(s);
date of birth, or age;
level of education;
employment details such as employer, job role, and job sector;
information collected directly from you through a transaction or inquiry, or submission of a form or registration to SNA Toolbox;
information about you from your organisation (e.g., school data on your academic performance, classroom membership);
your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
information you provide to us through surveys, including information about your networks and social connections; and
any other personal information that may be required in order to facilitate your dealings with us.
If you are an Authorised User, then we may also collect:
- Registration information – which includes your email address, mobile number, full name, organisation, role and country as this is the information required to register your Account; and
- Billing information - If you make a payment to us, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g., a credit card number and expiration date or a bank account number).
We may collect Sensitive Information from you which may include information or an opinion about your:
racial or ethnic origin;
political membership, associations or opinions;
religious or philosophical beliefs or affiliations;
membership of a professional association or trade union;
sexual orientation or practices;
criminal record; or
health information and genetic or biometric information.
4. How we use your information
We use and disclose Personal Information for the purposes for which the information is collected, or for a directly related purpose.
This includes (but is not limited to):
operating the Site and providing the Services;
disclosure as contemplated or required under any additional project terms that we agree in relation to a specific project, program or initiative;
administering, protecting, improving products and services (including performing data analytics and for conducting research;
responding to any inquiries or comments that users submit to us;
any other purpose that you specifically consent to; and
any use which is required or authorised by law.
We aggregate response data and activity so that we can identify trends, conduct research and provide our Services. We also extract and analyse usage patterns – to improve the Services and user experience.
5. Disclosure of Personal Information
We may disclose Personal Information to:
the Authorised User associated with the survey you have completed;
any person or entity to whom you have consented to us disclosing your Personal Information to; and
our legal advisors, and any other person or entity to whom we are required or authorised to disclose your personal information to in accordance with the law.
If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.
6. Direct marketing
In respect of Authorised Users, where we:
have your express consent - which you may withdraw at any time by contacting us (see Section 14: Contact information);
have a legal basis; or
are otherwise permitted by relevant Privacy Laws,
then we may use and process your Personal Information to send you information about our Products and Services. At any time, you may opt out of receiving direct marketing communications from us.
Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing (see Section 11: Contact information).
We don’t send direct marketing to Participants.
7. SNA Toolbox website and other tools
When transmitting personal information from your computer to us, you must keep in mind that the transmission of information over the Internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.
The Site may contain links to other third-party websites including social media networks.
We and our partners use cookies and similar technologies on our websites. We use certain cookies, as described here in our Privacy Policy, that you agree to when you use our sites and, in the case of some cookies, for legitimate interests of delivering and optimizing our services (where the cookie delivers essential functionality). Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:
to gather metrics about your survey taking experience
to make our site easier to use
for security reasons
to provide you with personalized content
to improve our services.
Google Analytics
In addition to the above, we have implemented on our websites and other services certain Google Analytics features that support display advertising, including re-targeting. Visitors to our Site may opt out of certain types of Google Analytics tracking by viewing its Customer Ads Help Centre. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on. You can choose to remove or disable cookies via your browser settings.
8. Data Storage and Security
We may hold your Personal Information in either electronic or hard copy. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your Personal Information. For example, SNA Toolbox restricts access to Personal Information only to authorised personnel and stores Personal Information on password protected computers and by using encryption technology. However, we cannot guarantee the security of any Personal Information transmitted over the internet.
We retain your personal information for as long as it is reasonably necessary to fulfil our business activities and then once it is no longer required, we securely destroy your personal information. We may retain personal information with the agreement of the organisation from which we collected the information to provide further services and benchmarking of data.
9. Cross-border Disclosure
We may collect Personal Information from Users based anywhere in the world.
We may disclose your Personal Information to third party recipients located in or outside of Australia – these are service providers that enable us to provide our website, products and services to you. As at the date of this Privacy Policy, such third-party recipients are located in Australia (Recipients).
10. Access to and correction of information
You can request us to:
correct any Personal Information we hold about you that is inaccurate or incomplete; and
provide you with access to Personal Information about you that we hold.
To exercise your rights, please contact us. See Section 11: Contact information. Should we decline your request for access to or correction of your Personal Information, we will provide a written explanation setting out our reasons for doing so.
We may charge a reasonable fee that is not excessive to cover the charges of retrieving your Personal Information from our customer account database. We will not charge you for making the request.
If you believe we hold Personal Information about you that is not accurate, complete or up-to-date, you may request that your Personal Information is updated. We will respond to your request to correct your Personal Information within a reasonable timeframe and you will not be charged a fee for requesting a correction to your Personal Information.
11. Contact information
If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact SNA Toolbox’s Privacy Coordinator Dean Lusher by post at PO Box 2278 Caulfield Junction VIC 3161 or via email to: deanlusher@snatoolbox.com.
12. Notices and Revisions
We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice. Non-material changes and clarifications will take immediate effect, and material changes will take effect 30 days after the posting of the amended Privacy Policy on the Site.
13. Enforcement
We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personally identifiable information that cannot be resolved between us and the individual.
Dated: July 2024